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Shedrick Chandler v. CSC Appied Technologies, L. L .C.
376 S.W.3d 802
Tex. App.
2012
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Background

  • Chandler, an African-American employee, sues CSC Applied Technologies for race discrimination and retaliation under the TCHRA after his non-selection for an Afghanistan WB-57 trip and his termination.
  • CSC moved for traditional and no-evidence summary judgment; the trial court sustained most objections and granted summary judgment for CSC.
  • Chandler alleged CSC favored two Caucasian alternates over him for the trip, and later terminated him for allegedly unauthorized overtime following an investigation.
  • Payne investigated Chandler’s overtime; Armstrong, Lanmon, Lankford, and Wyckoff provided statements; Chandler admitted some inconsistent explanations and leaving early without proper authorization.
  • CSC asserted the trip decision was based on qualifications and that the termination was based on legitimate, non-discriminatory reasons following an investigation; Chandler argued these were pretexts for discrimination and retaliation.
  • The appellate court applies de novo review to no-evidence and traditional summary-judgment standards and concludes CSC is entitled to judgment on both race-discrimination and retaliation claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did CSC discriminate based on race regarding the Afghanistan trip? Chandler argues non-protected comparators and pretext show discrimination. CSC argues qualifications—not race—drove trip selections; no evidence of race-based discrimination. No material pretext; trip not discriminatory
Did Chandler establish retaliation for opposing discrimination? Chandler contends he complained about not being on the list due to race and was fired in retaliation. Chandler did not prove protected activity tied to race; no but-for link; termination based on overtime investigation. No retaliation; protected activity not proven

Key Cases Cited

  • McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes burden-shifting framework for discrimination cases)
  • Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext requires more than false reasons; must show intentional discrimination)
  • Greathouse v. Alvin Indep. Sch. Dist., 17 S.W.3d 419 (Tex. App.—Houston [1st Dist.] 2000) (shifts burden and requires non-discriminatory reasons to be credible)
  • Elgaghil v. Tarrant Cnty. Junior College, 45 S.W.3d 133 (Tex. App.—Fort Worth 2000) (proximity and credibility of reasons; pretext analysis guidance)
  • Waggoner v. City of Garland, 987 F.2d 1160 (5th Cir. 1993) (investigation-based discharge requires showing good faith in decision-making; pretext when reliance on false allegations)
  • City of Waco v. Lopez, 259 S.W.3d 147 (Tex. 2008) (retaliation requires but-for causal link between protected activity and adverse action)
Read the full case

Case Details

Case Name: Shedrick Chandler v. CSC Appied Technologies, L. L .C.
Court Name: Court of Appeals of Texas
Date Published: Jul 12, 2012
Citation: 376 S.W.3d 802
Docket Number: 01-10-00667-CV
Court Abbreviation: Tex. App.