Edie Crain v. Smithville Regional Hospital and James W. Langford
Edie Crain, a former administrator for Smithville Regional Hospital, appealed a summary judgment in favor of the Hospital. Crain was terminated after sustaining a back injury at work and reported it. She alleged retaliatory discharge and argued the Hospital waived sovereign immunity by failing to provide workers' compensation insurance as required for political subdivisions. The court affirmed the district court's judgment, holding that the Hospital did not waive its sovereign immunity by non-compliance with the Workers' Compensation Act and, as a nonsubscribing employer, was not subject to the anti-retaliation provisions of the Texas Labor Code.