Martin v. Texas Dental Plans, Inc.
Charles Martin, a former typesetter for Texas Dental Plans, Inc., sued his employer for wrongful termination after he was fired shortly after filing a workers' compensation claim and an OSHA complaint regarding unsafe computer monitors. The employer contended termination was due to poor performance and absenteeism. A jury found Texas Dental violated the Texas Workers’ Compensation Act but awarded no actual damages, leading to a take-nothing judgment at the trial court despite a finding of willful conduct and $100,000 in punitive damages. On appeal, the court affirmed the denial of monetary and punitive damages but reversed the trial court's decision, ordering Martin's reinstatement. The appellate court clarified that reinstatement is a mandatory remedy when a Labor Code violation is found, irrespective of actual monetary damages.