Former teacher files discrimination suit against charter school

A teacher sued her former employer, a charter school, alleging she was subjected to race-based discrimination, a hostile work environment and retaliation. The charter school requested that the lawsuit be dismissed, and the trial court denied that motion. The charter school filed an appeal to the court of appeals.

The teacher, an African American female, was previously employed by the charter school as a seventh grade science teacher. During her employment, she complained about the manner in which the director of academics treated her. After the teacher raised these concerns, the campus principal placed her on a growth plan. The principal later resigned, and the new principal supervised the growth plan. The new principal extended the teacher's growth plan.

An incident occurred in which the teacher intervened during a physical altercation between two students. The teacher was accused of using physical force against a student and placed on administrative leave. Following her return to work, the teacher submitted a complaint to human resources, but no action was taken. The teacher subsequently received "low IER scores" and was eventually terminated from the charter school at the end of the school year.

The teacher filed a charge of discrimination with both the Equal Employment Opportunity Commission (EEOC) and the Texas Workforce Commission (TWC). She received a right-to-sue letter and filed her original petition in district court, alleging 16 causes of action against the charter school, including discrimination, hostile work environment, retaliation, intentional infliction of emotional distress, negligent infliction of emotional distress, disparate treatment, constructive discharge, wrongful termination, discrimination based on national origin, and defamation. 

The charter school responded by arguing that the lawsuit should be dismissed because a charter school is immune from suit. The charter school further asserted that it was immune from the teacher's claims because she failed to exhaust her administrative remedies. 

The district court denied the request to dismiss the lawsuit and the charter school appealed.

The court of appeals reviewed the claim and determined that the teacher did not include enough background facts in her complaint to the EEOC to allow the lawsuit to proceed. 

In order to properly exhaust administrative remedies related to this type of claim, a potential plaintiff must first file a charge with the EEOC, the TWC, or both. Although the teacher did this, her charge was deficient. 

A lawsuit that is filed after receiving a right-to-sue letter from the EEOC is limited to claims made in the charge filed with the EEOC or the TWC and factually related claims that can reasonably be expected to grow out of the agency's investigation. 

In this case, the teacher simply alleged the following:

"I believe I was target [sic] inside the organization by the Director of Academics, she would talk to the caucasian staff, while directly ignoring me in person and through the messaging tools provided by the school, among other discriminatory and retaliatory conduct. I believe I have been discriminated against in violation of Texas Labor Code, Chapter 21 and Title VII of the Civil Rights Act of 1964 as Amended based on my color/national origin/race and retaliation for exercising my protected rights."

Since the EEOC and TWC complaint did not contain enough factual information, the court concluded that the teacher failed to exhaust her administrative remedies. It then noted that the claims that were not related to discrimination, such as intentional infliction of emotional distress and constructive discharge, could not proceed because the charter school was immune from suit. 

The court of appeals therefore overturned the decision of the district court and ordered that the lawsuit be dismissed.