Ronald Heggemeier v. Caldwell County, Texas
2016 U.S. App. LEXIS 11531
| 5th Cir. | 2016Background
- Heggemeier, a white male, worked for Caldwell County, Texas—hired as assistant district attorney (Mar 2010) and promoted to County Administrator (Oct 2011).
- He complained to the Commissioners Court in Aug 2011 that the County’s dependent-health benefit policy disparately impacted older employees (ADEA-related) and later reported alleged improprieties (basis for a state whistleblower claim).
- In May 2013 the Commissioners Court terminated Heggemeier by abolishing the County Administrator position; a Hispanic employee (Chavira) was terminated eight days earlier but received substantially more severance and notice.
- Heggemeier sued under Title VII (race discrimination), the ADEA (retaliation), 42 U.S.C. § 1983 (wrongful termination/due process), and the Texas Whistleblower Act.
- The district court dismissed the § 1983 claim, granted summary judgment for defendants on the federal claims, and declined supplemental jurisdiction over the state whistleblower claim.
- The Fifth Circuit affirmed in all respects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII race discrimination — prima facie comparator | Heggemeier: treated less favorably than Chavira (Hispanic) — disparate notice/severance shows discrimination | County: Chavira and Heggemeier were not similarly situated (different tenure, roles, circumstances); both lost jobs in a reduction-in-force | Affirmed: no prima facie case — comparators not "nearly identical"; Title VII claim dismissed |
| ADEA retaliation — causation | Heggemeier: his complaint about insurance motivated termination | County: same actors involved in hiring and later decision, long (21-month) gap, legitimate nonretaliatory reason (cost savings) | Affirmed: no causal link; timing too remote and same-actor inference undermines retaliation claim |
| § 1983 — property interest in employment | Heggemeier: county policies/AG opinions and personnel §3.03 created an express limitation on at-will termination (property interest) | County: Texas presumes at-will employment; AG opinions and personnel policy do not expressly abrogate at-will status | Affirmed: no constitutionally protected property interest; §1983 claim dismissed |
| Supplemental jurisdiction over state whistleblower claim | Heggemeier: state claim should proceed | County: federal claims dismissed so court may decline pendant jurisdiction | Affirmed: district court did not abuse discretion in declining to exercise supplemental jurisdiction |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for circumstantial discrimination cases)
- Lee v. Kan. City S. Ry. Co., 574 F.3d 253 (definition of "similarly situated" for prima facie analysis)
- Clark Cty. Sch. Dist. v. Breeden, 532 U.S. 268 (temporal proximity must be "very close" to infer causation)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (ADEA requires but-for causation)
- Muncy v. City of Dall., 335 F.3d 394 (state law required to create property interest for § 1983 due-process claim)
- Zenor v. El Paso Healthcare Sys., Ltd., 176 F.3d 847 (Texas presumption of at-will employment)
- Brookshire Bros. Holding, Inc. v. Dayco Prods., Inc., 554 F.3d 595 (discretion to decline supplemental jurisdiction after federal claims dismissed)
- McCoy v. City of Shreveport, 492 F.3d 551 (direct vs. circumstantial evidence in Title VII context)