Tammy Anderson v. Houston Community College System and Johnella R. Bradford, Individually, 458 S.W.3d 633

Anderson sued HCC and Bradford for race and gender discrimination, harassment, and retaliation under the TCHRA.
Bradford, as Dean, supervised Anderson; OIE investigated and found evidence supporting discrimination/harassment by Bradford, leading to corrective action.
Anderson alleged Bradford used a racial slur, enforced a separate dress code by gender, and made weight-related comments.
HCC and Bradford moved for pleas to the jurisdiction and for summary judgment; the trial court granted all motions and awarded Bradford fees against Anderson.
Anderson appealed challenging the immunity ruling, jurisdiction over Bradford, and the merits on discrimination, hostile environment, retaliation, and fees.
On appeal, the court affirmed, holding no waiver of immunity, Bradford not personally liable, and no genuine fact issues on TCHRA claims or retaliation; attorney’s fees upheld as proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does TCHRA waive governmental immunity for HCC?	Anderson pleaded facts showing a TCHRA claim against HCC.	HCC immunity remains; no prima facie TCHRA elements proven.	No waiver; summary judgment for HCC proper.
Is Bradford personally liable under the TCHRA?	Bradford as supervisor identified as a respondent in EEOC charge; liable individually.	Individual cannot be liable; only employer can be liable.	Bradford not liable in her individual capacity; judgment proper.
Did Anderson raise a fact issue on race/gender discrimination claims?	OIE report and findings create fact issues; direct/circumstantial evidence of discrimination.	Actions were not adverse employment decisions; no prima facie case shown.	No fact issue; no discrimination shown under TCHRA.
Did Anderson raise a fact issue on hostile work environment?	Racial slur and gendered comments created pervasive harassment affecting environment.	Harassment not severe or pervasive enough to alter conditions of employment.	No hostile work environment; summary judgment for HCC proper.
Did Anderson raise a fact issue on retaliation claim?	Protected activities (OIE/EEOC) caused adverse actions.	No materially adverse action or causal link shown.	No retaliation; summary judgment proper.

Winters v. Chubb & Son, Inc., 132 S.W.3d 568 (Tex. App.—Houston [14th Dist.] 2004) (adverse employment decisions define TCHRA scope; not every workplace action)
Chandler v. CSC Applied Techs., LLC, 376 S.W.3d 802 (Tex. 2012) (McDonnell Douglas burden-shift; direct vs. circumstantial evidence; retaliation framework)
Elgaghil v. Tarrant Cnty. Junior Coll., 45 S.W.3d 133 (Tex. App.—Fort Worth 2000, pet. denied) (TCHRA analysis; ultimate employment decisions; pretext guidance)
Toennies v. Quantum Chem. Corp., 47 S.W.3d 473 (Tex. 2001) (TCHRA analysis; alignment with Title VII standards)
Willrich v. MD Anderson Hosp. & Tumor Inst., 28 S.W.3d 22 (Tex. 2000) (stray remarks not enough to prove pretext; timing proximity matters)