Stephen Miller v. Metrocare Services
809 F.3d 827
| 5th Cir. | 2016Background
- Stephen Miller, Metrocare HR Director, was hired in 2006; while employed he reclassified case managers as non-exempt under the FLSA and investigated overtime complaints.
- Metrocare requires one-time and annual criminal background checks; Munson (CFO) found Miller had removed himself from annual checks (2010–2012), failed to run checks for ~70 employees (Dec. 2012), and altered MUNIS records to show checks were cleared.
- Metrocare terminated Miller in February 2013 for falsifying background-check records and exempting himself from required checks; Miller requested and received a post-termination “name-clearing” hearing before the Board but was not reinstated.
- Miller sued under the FLSA, FMLA, ADA, Texas Labor Code, later adding § 1983 procedural due process and a Texas Health & Safety Code § 161.134 claim; district court dismissed the Health & Safety Code claim and granted summary judgment for defendants on the remaining claims.
- On appeal, the Fifth Circuit reviewed de novo and affirmed: employer proffered a legitimate nondiscriminatory reason (failure to run/record background checks); Miller failed to show pretext or deficient name-clearing process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FLSA/FMLA retaliation/interference | Miller argues he was fired in retaliation for complaining about misclassification/overtime and for FMLA-protected activity | Metrocare contends it terminated Miller for legitimate nondiscriminatory reasons—failing to run and falsifying background checks | Summary judgment for Metrocare; Miller failed to show pretext |
| ADA failure-to-accommodate/disability discrimination | Miller contends dyslexia and request for a data-entry clerk (or rehiring Reyna) were protected and motivated termination | Metrocare asserts data-entry was an essential job function after reductions and rehiring a laid-off employee was not a reasonable accommodation | Summary judgment for Metrocare; requested accommodation was not reasonable and Miller did not show discrimination |
| § 1983 procedural due process (name-clearing) | Miller claims inadequate notice, inability to confront witnesses, secret evidence, and denial of an adequate forum to clear his name | Metrocare argues Miller received adequate post-termination notice and a meaningful name-clearing hearing where counsel presented evidence and argument | Summary judgment for Metrocare; hearing was adequate and plaintiff’s stigma-plus claim failed |
| Texas Health & Safety Code § 161.134 claim (jurisdictional) | Miller asserted statutory claim against Metrocare | Metrocare asserted governmental immunity; district court dismissed under Rule 12(b)(1) | Dismissal affirmed (claim barred by immunity / not actionable) |
Key Cases Cited
- Feist v. La. Dep’t of Justice, Office of the Att’y Gen., 730 F.3d 450 (5th Cir. 2013) (summary judgment standard and ADA failure-to-accommodate framework)
- Juino v. Livingston Parish Fire Dist. No. 5, 717 F.3d 431 (5th Cir. 2013) (view facts in light most favorable to nonmovant on summary judgment)
- Bledsoe v. City of Horn Lake, 449 F.3d 650 (5th Cir. 2006) (liberty interest and name-clearing/hearing principles for public employees)
- Hughes v. City of Garland, 204 F.3d 223 (5th Cir. 2000) (stigma-plus test elements for § 1983 liberty-interest claims)
- Bellard v. Gautreaux, 675 F.3d 454 (5th Cir. 2012) (application of stigma-plus framework to discharged public employees)
- Reed v. Neopost USA, Inc., 701 F.3d 434 (5th Cir. 2012) (appellate affirmation of summary judgment on any record-supported ground)