Garcia v. Levi Strauss & Co.
Rosa Garcia appealed the trial court's summary judgment dismissing her discrimination claims against Levi Strauss & Co. under Tex. Lab.Code Ann. § 451.001. Garcia alleged that after sustaining multiple on-the-job injuries and filing workers' compensation claims, her pay was significantly reduced and she was subjected to a hostile work environment. Levi Strauss contended the pay reduction was due to its legitimate inactive status policy and denied the hostile environment claim. The appellate court affirmed the summary judgment, finding that Garcia did not raise a fact question on discriminatory application of the inactive status policy. While acknowledging hostile work environment claims are possible under Section 451, her evidence did not establish sufficiently severe or pervasive harassment to affect her employment conditions.