Teresa Thompson v. Somervell County, Texas, 431 F. App'x 338

Thompson began working for Somervell County in 1995 and became Assistant County Auditor in 1996.
She alleged sexual harassment by County Auditor Morrison in August 2005, reported it, then chose not to pursue after Morrison apologized.
Thompson transferred to the Expo Center in 2008 and faced performance problems while in that role.
On May 4–11, 2009, Thompson requested her personnel file, including the 2005 harassment report, signaling a potential change in position.
Dooley reprimanded Thompson on May 18–19, 2009 for deficient work and terminated her on June 2, 2009 after a failure to improve.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thompson engaged in protected activity under Title VII retaliatory framework	Thompson sought documentation of the harassment report as opposition to discrimination	The request was made to justify a new county job, not to oppose discrimination	No, not protected activity under Title VII
Whether Thompson established a causal link between protected activity and termination	Temporal proximity supports causation	Dooley lacked knowledge of Thompson's protected activity when firing her	No causal link; knowledge of protected activity absent

Douglas v. DynMcDermott Petroleum Operations Co., 144 F.3d 364 (5th Cir. 1998) (protected activity defined; opposition not shown here)
Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337 (5th Cir. 2007) (McDonnell Douglas framework in retaliation cases)
Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (temporal proximity requires close knowledge by decision maker)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for retaliation claims)
Crawford v. Metro. Gov’t of Nashville & Davidson Cnty., Tenn., 129 S. Ct. 846 (2009) (opposition requires purposive conduct)
Hockman v. Westward Commc’ns., LLC, 407 F.3d 317 (5th Cir. 2004) (reiterates prima facie burden and shifting burden)