Taliaferro v. Lone Star Implementation & Electric Corp., 693 F. App'x 307

Dana Taliaferro was Controller at Lone Star for ~1 year; Lone Star's owner Ronnie Hobbs sent sexually suggestive text messages to her, which strained her marriage.
After complaining and requesting time off, Hobbs terminated Taliaferro by text two days later; she alleged emotional distress and ~10 weeks to find new work.
Taliaferro filed an EEOC charge, received a right-to-sue, and sued Lone Star asserting Title VII retaliation (opposition clause) and a breach-of-contract claim under the Employee Handbook. District court dismissed the Title VII claim under Rule 12(b)(6) and declined supplemental jurisdiction over the contract claim.
On appeal Taliaferro argued the district court failed to consider Lone Star’s Employee Handbook "zero tolerance" sexual harassment policy when assessing whether she reasonably believed Hobbs’s conduct was an unlawful employment practice. She appealed only the Title VII dismissal.
The core legal question: whether, viewing the handbook plus the facts alleged (a single sexually suggestive text exchange), Taliaferro plausibly pleaded a reasonable belief that Title VII was violated such that her opposition was protected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint plausibly alleges a reasonable belief that Hobbs’s texts were an unlawful practice under Title VII (opposition clause)	Taliaferro: company "zero tolerance" handbook + the texts made her belief objectively reasonable	Lone Star: single isolated, non-explicit exchange is insufficient; handbook does not transform lawful-but-offensive conduct into Title VII violation	Affirmed dismissal: handbook may be considered but does not make a single text an objectively reasonable belief of a Title VII violation

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (establishes plausibility standard for Rule 12(b)(6))
Clark County School Dist. v. Breeden, 532 U.S. 268 (single, isolated remark insufficient for harassment claim)
E.E.O.C. v. Rite Way Serv., Inc., 819 F.3d 235 (consider totality of circumstances, including employer policy, in assessing reasonableness)
Aryain v. Wal-Mart Stores Tex. LP, 534 F.3d 473 (elements of retaliation claim)
Douglas v. DynMcDermott Petroleum Operations Co., 144 F.3d 364 (defines opposition and participation clauses)
Chhim v. Univ. of Tex. at Austin, 836 F.3d 467 (de novo review of 12(b)(6))
New Orleans v. Ambac Assurance Corp., 815 F.3d 196 (pleading standards and view of well-pleaded facts)
Satterwhite v. City of Houston, [citation="602 F. App'x 585"] (single isolated comment may be insufficient to support reasonable belief)