Julie T. Chau v. Select Medical Corporation D/B/A Regency Hospital of Odessa, LLP
Julie T. Chau sued her employer, Select Medical Corporation d/b/a Regency Hospital of Odessa, LLP, alleging discrimination based on race, national origin, and age, along with retaliation. The trial court granted summary judgment for Regency, determining Chau's petition was untimely filed under the statute of limitations. On appeal, Chau contested this ruling, asserting that her filing was timely under the mailbox rule of Rule 5 of the Texas Rules of Civil Procedure. The Eleventh Court of Appeals reviewed whether the mailbox rule applied to the Texas Labor Code's limitations period and whether Chau provided sufficient evidence for compliance. The appellate court held that the mailbox rule does apply and found that Chau's attorney's affidavit and attached documents raised a material question of fact regarding the timeliness of the filing. Consequently, the court reversed the trial court's summary judgment and remanded the case for further proceedings.