In Alford v. Wonderland Montessori Academy, LLC, 2024 WL 4354711 (N.D.Tex. Sept. 30, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s claim of retaliation under Title VII of the Civil Rights Act of 1964.
From the decision:
Alford alleges that she engaged in protected activity “in reporting discrimination by Defendant’s employee and supervisor Ms. Jiwani to its Human Resources Generalist shortly before her performance review” and that Wonderland’s actions in “furloughing her in April 2020 and then terminating her employment in August 2020 were adverse and pretextual.” Compl. ¶¶ 50-51. She then specifically alleges that this “constituted retaliation in violation of Title VII of the Civil Rights act of 1964, as amended, 42 U.S.C. § 2000e-3 and 2000e-2(1) and Tex. Labor Code Ann[.] §§ 21.001-21.306 (Vernon 2006)” and that she suffered damages “[a]s a direct and proximate result of the Defendant’s intentional and racially discriminatory acts and/or omissions.” Compl. ¶¶ 53-54. The protected activity alleged in the complaint—reporting discrimination before her October 2019 performance review—allegedly occurred more than five months before her furlough in March 2020. Because Alford cites no other evidence of retaliation, she has failed to adduce evidence of a causal connection between her complaint in October 2019 and her furlough in March 2020 or her termination in August 2020.
Based on this, the court concluded that since plaintiff has not provided evidence to make her prima facie case for retaliation, summary judgment was warranted.