Reported / Citable
Background
Crystal Walker Green worked for CenterPoint Energy for 17 years and moved from a Credit Supervisor role to a Continuous Improvement Consultant position. CenterPoint said Green struggled in the new role, received coaching from her manager, Caroline Geiger, and was placed on a performance improvement plan in February 2024.
Green complained to Human Resources about the PIP and alleged that Geiger singled her out, denied her training and collaborative opportunities, and treated colleagues more favorably because of her race, age, national origin, and religion. CenterPoint terminated Green in May 2024 after its ethics-and-compliance investigation into her complaint concluded.
The Court’s Holding
Judge Andrew S. Hanen granted CenterPoint’s motion for summary judgment on all claims. The court held that Green had not pleaded an age-discrimination claim under the Age Discrimination in Employment Act; alternatively, the record did not support a prima facie age claim because Green did not know whether she was replaced by a younger person, and her supervisors made no age-related comments.
Assuming Green intended to assert Title VII retaliation, the court held that she did not create a fact issue on causation or pretext. Her performance concerns and PIP predated her HR complaint, and the termination decisionmakers were not told of the nature of the ethics complaint or that Green had made it. The court also rejected her race-discrimination claim because she identified no nearly identical comparator who was treated better, and the documented performance record, without evidence of racial bias, did not permit an inference of pretext.
Key Takeaways
- A plaintiff cannot proceed on an age-discrimination theory without pleading a claim under the ADEA or supplying evidence supporting its essential elements.
- Temporal proximity alone did not establish retaliation where discipline began before the protected activity and continued through termination.
- For a Title VII comparator case, employees in different roles or with materially different disciplinary histories are not similarly situated.
Why It Matters
The decision illustrates the importance of contemporaneous performance documentation in employment cases. A plaintiff’s disagreement with an employer’s assessment of performance, standing alone, does not establish that the stated reason for termination was a pretext for discrimination or retaliation.