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Mato v. Baldauf

An employee who claimed that university officials discharged her in retaliation for helping other female employees file sexual harassment claims failed to present sufficient evidence to permit a jury to reasonably infer that the university's justification for terminating her position was a pretext for retaliation.

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Appeals from the United States District Court for the Western District of Texas

A jury found that Texas A&M University terminated Christine Mato’s employment in retaliation for helping female employees file sexual harassment complaints, and then awarded Mato approximately $216,000 for lost wages and $250,000 for pain and suffering. The district court entered judgment and awarded Mato attorneys’ fees and costs in the amount of $50,000, which was less than one-fourth of what she had requested. Both parties have appealed. Texas A&M contends that (1) Mato failed to provide sufficient evidence of a causal connection between her protected Title VII activity and her discharge from employment; and (2) Mato’s evidence regarding pain and suffering cannot justify the size of the jury’s mental anguish award. Mato has filed a cross-appeal, contending that the district court abused its discretion by reducing her request for attorney’s fees. We conclude that Mato has failed to present sufficient evidence to support a causal connection between her protected activity and her discharge. We therefore reverse and remand for entry of a judgment dismissing the complaint.

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