In Armijo v. Bee County, Texas, No. 2:25-CV-00103, 2026 WL 3218648 (S.D. Tex. Oct. 27, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment and quid pro quo sexual harassment claims asserted under Title VII of the Civil Rights Act of 1964.
In sum, plaintiff alleges her supervisor sexually harassed her, disciplined her after she refused his advances, and ultimately fired her after she reported the harassment.
As to plaintiff’s hostile work environment claim, the court explained:
Defendant moves for summary judgment on Plaintiff’s hostile work environment claim, contending both that Plaintiff has failed to establish her prima facie case and that Defendant is entitled to the Faragher-Ellerth affirmative defense. The Court disagrees.
As to Plaintiff’s prima facie case, Defendant argues that the alleged harassment “did not affect a term, condition, or privilege of employment.” Specifically, Defendant points to Chief Deputy Jones’ testimony that an independent investigation found the disciplinary write-ups against Plaintiff were justified.
In response, Plaintiff highlights her deposition testimony that she was disciplined because she turned down Bullock’s advances. Specifically, Plaintiff describes that she was disciplined for allowing an inmate to obtain a multi-tool, despite not being on the premises during that alleged incident. Id. Plaintiff and Defendant therefore present conflicting evidence of the reason for the disciplinary action, creating a genuine dispute of material fact as to whether the alleged harassment affected a term, condition, or privilege of employment.
As to Defendant’s Faragher-Ellerth affirmative defense, the Court finds that genuine disputes of material fact again preclude summary judgment. Defendant points to its policies and procedures to prevent and correct sexual harassment in the workplace. Plaintiff, however, has provided competent summary judgment evidence that she was forced to work alongside Bullock even after submitting her complaint. [At her deposition, plaintiff testified] that Bee County officials “forced” Plaintiff to work alongside Bullock after she filed a complaint and told her to “yell and scream” if Bullock harassed her again.
Thus, although Defendant’s policies may be sufficient to show Defendant took reasonable steps to prevent sexual harassment, Plaintiff has created a fact dispute as to whether Defendant exercised reasonable care to prevent and correct the sexual harassment.
(Cleaned up.)
The court likewise denied defendant’s motion for summary judgment as to plaintiff’s quid pro quo sexual harassment claim, but granted defendant’s motion for summary judgment on plaintiff’s retaliation claim.