Wilson v. Noble Drilling Services, Inc., 405 F. App'x 909

Wilson, employed by Noble since 1997, faced potential FMLA leave for his newborn's care in 2008.
Wilson warned Hoffman and Owen that he might need leave, repeatedly, without detailing timing or duration.
January 2008: Wilson promoted to Domestic Marketing Manager; February 2008: he complained about the raise to Madden.
Wilson was terminated February 22, 2008 after disputes over protocol and an open-door policy.
Noble paid 2007 STIP bonuses on February 27, 2008; eligibility required employment on that date, which Wilson lacked.
Wilson sued in district court alleging FMLA retaliation and breach of contract; district court granted summary judgment for Noble.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wilson proved FMLA retaliation	Wilson asserts protected activity followed by adverse action.	Noble asserts no protected FMLA notice and a legitimate reason for firing.	No prima facie case; no protected activity proven; no retaliation.
Whether Noble's termination was pretext for retaliation	Close timing and post-promotion treatment show pretext.	Timing alone is insufficient; legitimate reason exists and contemporaneous review supports it.	No triable issue on pretext; summary judgment affirmed for FMLA claim.
Whether Noble breached the STIP contract by not paying a 2007 bonus	Texas contract law should enforce a pro rata bonus despite termination.	Contract unambiguously requires employment on the bonus date to receive payment; Wilson was fired beforehand.	No breach; contract unambiguous and enforced as written; not entitled to 2007 STIP bonus.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court, 1973) (burden-shifting framework for discrimination claims)
Mauder v. Metro. Transit Auth. of Harris Cty., 446 F.3d 574 (5th Cir. 2006) (FMLA retaliation framework applied by this circuit)
Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (Supreme Court, 2000) (pretext evaluation after prima facie case)
Shackelford v. Deloitte & Touche, LLP, 190 F.3d 398 (5th Cir. 1999) (close timing must be accompanied by non-pretextual justification)
Swanson v. GSA, 110 F.3d 1180 (5th Cir. 1997) (close timing may establish causal connection in prima facie case)
Miller v. Riata Cadillac Co., 517 S.W.2d 773 (Tex. 1974) (pro rata bonus recovery under oral contract facts)
U.S. Fire Ins. Co. v. Confederate Air Force, 16 F.3d 88 (5th Cir. 1994) (enforcement of unambiguous written contracts as written)
Interstate Contracting Corp. v. City of Dallas, 407 F.3d 708 (5th Cir. 2005) (interpretation of unambiguous contracts; reliance on contractual terms)
Roberson v. Alltel Information Services, Inc., 373 F.3d 647 (5th Cir. 2004) (pretext and timing considerations in retaliation claims)
Richardson v. Monitronics International, Inc., 434 F.3d 327 (5th Cir. 2005) (mixed-motive framework discussion in FMLA context)