Jose Luis Pena v. County of Starr
Jose Luis Pena appealed a summary judgment granted in favor of his former employer, Starr County, on his claims for retaliatory discharge, discrimination, and violation of the Family Medical Leave Act (FMLA). Pena was terminated after taking an extended medical leave due to complicated surgery, following an earlier back injury for which he filed a workers' compensation claim. The appellate court affirmed the summary judgment for age discrimination and the retaliatory discharge claim, the latter due to lack of subject matter jurisdiction against a governmental entity under the Texas Workers' Compensation Act. However, the court reversed and remanded the summary judgment regarding Pena's FMLA claim and his discrimination claim based on disability. The FMLA claim was deemed timely under the relation-back doctrine, and the disability discrimination claim was reversed because the County failed to address all aspects of Pena's alleged disability in its motion.