Waffle House, Inc. v. Williams
Cathie Williams sued her employer, Waffle House, Inc., for sexual harassment under the Texas Commission on Human Rights Act (TCHRA) and negligent supervision/retention after enduring offensive comments and physical contact from a coworker, Eddie Davis. Despite Williams' complaints to management, the harassment continued, leading to her constructive discharge. A jury found in favor of Williams on both claims, awarding significant damages for the common-law claim. However, the Supreme Court reversed the court of appeals' judgment, ruling that the TCHRA's specific and tailored anti-harassment remedy is preemptive when negligence is entwined with harassment. The Court held that Williams' common-law claim was based on the same conduct as her TCHRA claim and that allowing it would undermine the Legislature's comprehensive statutory scheme. The case was remanded to the court of appeals to address the statutory sexual harassment issues.