In Raylane v. Integra Staffing Services, Inc. & Republic Services, Inc., No. 3:24-CV-3051-X, 2026 WL 2790785 (N.D. Tex. Sept. 17, 2026), the court, inter alia, held that plaintiff sufficiently alleged retaliation under Title VII of the Civil Rights Act of 1964.
The court summarized the facts as follows:
Integra provides temporary staffing to various companies, including Republic. In June of 2024, Integra assigned Raylane to Republic, where she worked seventeen days. Raylane alleges that during her employment, Roger, a Republic employee, would “follow [her] into her workplace and distract her from her duties by making unwelcome personal comments.” Raylane asserts that on or around July 1, 2024, Roger followed her into her workplace and continued to make unwelcome comments, then on his way out, “grabbed [her] around the waist, squeezed her and kissed her on the cheek.” Raylane immediately reported Roger’s behavior to two supervisors at Republic, who sent Raylane home. Raylane alleges that she also reported the incident to Integra, which then terminated her employment. Raylane asserts Integra and Republic terminated her in retaliation for her complaint about the “unwelcome advances and sexually hostile environment in the workplace.
(Citations omitted.)
In assessing plaintiff’s claim against Republic, the court explained:
Raylane clarifies her retaliation claim against Republic under 42 U.S.C. § 2000e-3, making it clear that she brings the claim against both Integra and Republic because they jointly retaliated against her after she reported Roger’s conduct. Republic makes two arguments against the retaliation claim, but neither argument prevails.
First, Republic incorrectly contends that Raylane brings a new retaliation claim against Republic because she failed to allege any retaliation claim against Republic in her First Amended Complaint. Raylane’s references to “Defendants” in her First Amended Complaint allows her to clarify her retaliation claim against Republic now.
Second, because Raylane sufficiently pleads facts upon which relief can be granted, Republic is wrong to assert that Raylane’s “allegations are vague, conclusory, and unsupported.” Title VII requires a plaintiff to show that (1) she participated in a protected activity, (2) she was subject to an adverse employment action, and (3) there was a causal connection between the protected activity and the adverse employment action. “The mere fact that some adverse action is taken after an employee engages in some protected activity will not always be enough for a prima facie case.” “Nevertheless, close timing between the protected activity and adverse action can establish the casual link required to assert a prima facie case.” The Fifth Circuit has “repeatedly held periods of a few months [are] sufficient to satisfy causation in a prima facie case.”
Raylane’s Second Amended Complaint alleges that “Republic declined to accept [her] for any further work after she made her complaint of sex harassment.” In Republic’s view, Raylane “fails to include any factual detail to support this conclusion.” But viewing the pleadings in the light most favorable to Raylane, the Court finds that she has alleged enough to survive Republic’s Motion to Dismiss.
Specifically, Republic refused to accept her for any work (an adverse employment action) after she complained to them about Roger’s unwelcome conduct (a protected activity). And the timing between the two activities indicates that they are directly related. Raylane need not plead an elaborate factual scheme describing in detail exactly how Republic worked to discriminate against her; her allegations in her Second Amended Complaint suffice.
(Citations omitted.)
Based on this, the court held that plaintiff’s retaliation claim survives, and, accordingly, denied Republic’s motion to dismiss that claim.
Furthermore, the court held that plaintiff’s retaliation claim against Integra is identical to her claim against Republic and survives for the same reasons.