Rodriguez v. Phillips 66 Company, 3:19-cv-00209

Rodriguez was hired by Phillips 66 in 2011 as an Operator and was terminated on June 8, 2018; Phillips 66 says termination was for repeated aggressive/unprofessional conduct and misrepresenting absences.
In spring 2017 Rodriguez took FMLA leave for a hand injury; Phillips 66 disciplined him after evidence of inconsistent activities and issued a Final Written Warning plus a seven-day suspension.
In April 2018 Rodriguez requested emergency vacation (claimed wife had a car accident), missed multiple shifts, and submitted sparse medical notes reflecting a neck/back contusion; he later admitted his wife’s accident claim was false.
Phillips 66 approved FMLA leave (backdated to April 10, 2018), requested supporting documentation and a medical exam; Rodriguez did not supply the requested documentation.
Rodriguez was cleared to return to full duty May 21 and passed a fitness-for-duty exam; on May 25 he became argumentative and allegedly yelled, pointed at HR, and was placed on administrative leave.
After an internal investigation and review of his disciplinary history (including the 2017 Final Written Warning), Phillips 66 terminated Rodriguez; he sued asserting ADA and TCHRA disability discrimination and retaliation, and FMLA interference and retaliation. The magistrate judge recommends granting Phillips 66’s motion for summary judgment and dismissing the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rodriguez is "disabled" under the ADA/TCHRA	Rodriguez says he suffered from spondylosis that limited walking/working	Phillips 66 points to medical clearance and fitness-for-duty showing no substantial limitation	Court: Rodriguez failed to show spondylosis substantially limited major life activities; not disabled
Whether Phillips 66’s stated reason for termination was pretext for discrimination	Rodriguez argues investigator hire, past nondiscipline, and temporal proximity show pretext	Phillips 66 contends it legitimately terminated for aggressive/unprofessional conduct and dishonesty about absences	Court: Employer offered a legitimate reason; plaintiff failed to produce other significant evidence of pretext
Whether Rodriguez was retaliated against (ADA, TCHRA, FMLA)	Rodriguez contends protected leave/activity led to adverse actions (suspension/termination)	Phillips 66 says adverse action resulted from misconduct and disciplinary history, not protected activity	Court: Even assuming prima facie case, Rodriguez failed to show pretext; summary judgment for defendant
Whether Phillips 66 interfered with Rodriguez’s FMLA rights	Rodriguez contends employer impeded or denied FMLA benefits	Phillips 66 says it approved FMLA leave, requested supporting documentation, and ultimately acted for nondiscriminatory reasons	Held: No genuine dispute that employer’s actions were for legitimate reasons; interference claim fails

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
Tex. Dep't of Community Affairs v. Burdine, 450 U.S. 248 (employer's production burden is one of articulation, not persuasion)
Frame v. City of Arlington, 657 F.3d 215 (ADA Title I overview and purpose)
EEOC v. LHC Grp., Inc., 773 F.3d 688 (application of McDonnell Douglas in ADA context)
Chevron Phillips Chem. Corp. v. EEOC, 570 F.3d 606 (definition and proof requirements for disability under ADA)
Goudeau v. Nat'l Oilwell Varco, L.P., 793 F.3d 470 (pretext requires evidence employer's explanation is false supporting but-for causation)
Musser v. Paul Quinn Coll., 944 F.3d 557 (temporal proximity alone insufficient to establish pretext at summary judgment)
LeMaire v. La. Dep't of Transp. & Dev., 480 F.3d 383 (courts should not second-guess reasonable business decisions of employers)