Colleen Paige Simmons v. Top Deck, Inc.
Colleen Simmons sued her former employer, Top Deck, Inc., for employment discrimination, alleging sexual harassment (quid pro quo and hostile work environment) and retaliation by a Top Deck employee, Justin Bufford. Simmons claimed Bufford requested sexually explicit photos and engaged in sexual banter, leading to a lack of work assignments. Top Deck moved for summary judgment, which the trial court granted. On appeal, the Court of Appeals affirmed the summary judgment, finding no genuine issues of material fact. The court concluded there was no evidence of quid pro quo harassment because the sexual text messages occurred after Simmons had already decided to cease employment. Furthermore, Top Deck successfully invoked the Faragher/Ellerth affirmative defense for the hostile work environment claim, as Simmons failed to report the alleged harassment through established company procedures. Finally, Simmons's retaliation claim failed because her actions did not constitute 'protected opposition' under the Texas Commission on Human Rights Act.