Montgomery County v. Park
David Park, a patrol lieutenant for Montgomery County, reported alleged sexual harassment by a County Commissioner. Following this report, Park's additional duties as a security coordinator for convention center events were reassigned. Park sued Montgomery County, claiming retaliation under the Texas Whistleblower Act, arguing that the reassignment constituted an adverse personnel action. The Texas Supreme Court adopted an objective standard for 'adverse personnel action,' requiring the action to be materially adverse enough to deter a reasonable, similarly situated employee from reporting a violation. The Court concluded that the loss of Park's first choice of convention center jobs did not meet this standard, as it did not impact his core job compensation, advancement, or overall access to extra work. Therefore, the Court reversed the court of appeals' judgment and ruled in favor of Montgomery County.