pretext doctrine (Texas) · Go Syfert
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pretext doctrine in Texas

22 Texas opinions name it 3 courts 1990–2026 2 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Garcia v. Stategreen
texcrimapp · 1992 · cited in 5 Texas opinions naming this issue, 1993–2015
2 sentences

2015In practical application, courts found it nearly impossible to determine the subjective intent of officers when making stops and arrests, so the pretext doctrine was explicitly abandoned in Garcia v. State, 827 S.W.2d 937, 944 (Tex. Crim.

2004In that case, we recognized explicitly that the pretext doctrine no longer invalidates a stop and that, in considering whether an offense has been committed, "an officer's subjective intent is relevant only to a credibility determination of his stated reasons for stopping or arresting an individual." Id. at *3; Garcia , 827 S.W.2d at 944 .

25
Laxton v. Gap Inc.green
ca5 · 2003 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010See Reeves v. Sanderson Plumbing Prods., Inc ., 530 U.S. 133, 147 (2000) (noting that "proof that the defendant's explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive"); Nasti v. CIBA Specialty Chems ., 492 S.W.3d 589, 594 (5th Cir. 2007) ("The pretext inquiry focuses on the authenticity of the employer's proffered reason."); Laxton v. Gap Inc. , 333 F.3d 572, 578 (5th Cir. 2003) ("A plaintiff may establish pretext . . . by showing that the employer's proffered explanation is false or '

2010See Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 147 (2000) (noting that “proof that the defendant’s explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive”); Nasti v. CIBA Specialty Chems., 492 S.W.3d 589, 594 (5th Cir. 2007) (“The pretext inquiry focuses on the authenticity of the employer’s proffered reason.”); Laxton v. Gap Inc., 333 F.3d 572, 578 (5th Cir. 2003) (“A plaintiff may establish pretext . . . by showing that the employer’s proffered explanation is false or ‘unw

22
Reeves v. Sanderson Plumbing Products, Inc.green
scotus · 2000 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010See Reeves v. Sanderson Plumbing Prods., Inc ., 530 U.S. 133, 147 (2000) (noting that "proof that the defendant's explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive"); Nasti v. CIBA Specialty Chems ., 492 S.W.3d 589, 594 (5th Cir. 2007) ("The pretext inquiry focuses on the authenticity of the employer's proffered reason."); Laxton v. Gap Inc. , 333 F.3d 572, 578 (5th Cir. 2003) ("A plaintiff may establish pretext . . . by showing that the employer's proffered explanation is false or '

2010See Reeves v. Sanderson Plumbing Prods., Inc ., 530 U.S. 133, 147 (2000) (noting that "proof that the defendant's explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive"); Nasti v. CIBA Specialty Chems ., 492 S.W.3d 589, 594 (5th Cir. 2007) ("The pretext inquiry focuses on the authenticity of the employer's proffered reason."); Laxton v. Gap Inc. , 333 F.3d 572, 578 (5th Cir. 2003) ("A plaintiff may establish pretext . . . by showing that the employer's proffered explanation is false or '

22
Mathis v. Stategreen
texcrimapp · 2002 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010See Batson, 476 U.S. at 106 ; see also Mathis v. State, 67 S.W.3d. 918, 924 (Tex. Crim.

2010See Batson, 476 U.S. at 106; see also Mathis v. State, 67 S.W.3d. 918, 924 (Tex. Crim.

22
Veronica A. Wallace v. The Methodist Hospital Systemgreen
ca5 · 2001 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010System , 271 F.3d 212, 220 (5th Cir. 2001)). 8. 8 There was also evidence that the superintendent gave Acosta a negative review, including that Acosta was a "troublemaker," which testimony conflicted with the testimony from other supervisors and the positive performance evaluations that Acosta received during his employment with the City.

2010System, 271 F.3d 212, 220 (5th Cir. 2001)). 9 discretion to accept a resignation immediately when it was in the “best interest” of the City and that is what happened here.

22
Russo v. Smith International, Inc.green
texapp · 2002 · cited in 3 Texas opinions naming this issue, 2004–2004
2 sentences

2004Russo, 93 S.W.3d at 435 .

2004Russo, 93 S.W.3d at 435 .

13
Kelly v. Boeing Petroleum Services, Inc.green
ca5 · 1995 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021Servs., Inc., 61 F.3d 350, 360 (5th Cir. 1995) (quoting Estes v. Dick Smith Ford, Inc., 856 F.2d 1097, 1103 (8th Cir. 1988)).

11
Cummings v. Standard Register Co.green
ca1 · 2001 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021See Cummings v. Standard Register Co., 265 F.3d 56, 63 (1st Cir. 2001); see also McDonnell Douglas, 411 U.S. at 804–05, 93 S. Ct. at 1825 (holding that the employer’s other discriminatory practices may inform the pretext inquiry). “[C]ircumstantial proof of discrimination typically includes unflattering testimony about the employer’s history and work practices—evidence which in other kinds of cases may well unfairly prejudice the jury against the defendant.” Kelly v. Boeing Petro.

11
Ruben Estes v. Dick Smith Ford, Inc.green
ca8 · 1988 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021Servs., Inc., 61 F.3d 350, 360 (5th Cir. 1995) (quoting Estes v. Dick Smith Ford, Inc., 856 F.2d 1097, 1103 (8th Cir. 1988)).

11
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 1 Texas opinions naming this issue, 2021–2021
2 sentences

2021See Cummings v. Standard Register Co., 265 F.3d 56, 63 (1st Cir. 2001); see also McDonnell Douglas, 411 U.S. at 804–05, 93 S. Ct. at 1825 (holding that the employer’s other discriminatory practices may inform the pretext inquiry). “[C]ircumstantial proof of discrimination typically includes unflattering testimony about the employer’s history and work practices—evidence which in other kinds of cases may well unfairly prejudice the jury against the defendant.” Kelly v. Boeing Petro.

2021See Cummings v. Standard Register Co., 265 F.3d 56, 63 (1st Cir. 2001); see also McDonnell Douglas, 411 U.S. at 804–05, 93 S. Ct. at 1825 (holding that the employer’s other discriminatory practices may inform the pretext inquiry). “[C]ircumstantial proof of discrimination typically includes unflattering testimony about the employer’s history and work practices—evidence which in other kinds of cases may well unfairly prejudice the jury against the defendant.” Kelly v. Boeing Petro.

11
LeMaire v. Louisiana Department of Transportation & Developmentgreen
ca5 · 2007 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015LeMaire v. Louisiana Dept. of Transp. & Deb. 480 F.3d 383, 391 (5th Cir. 2007) In order to demonstrate pretext, the plaintiff must do more than show that the employer made an incorrect decision; she must show that it made a discriminatory one.

11
Archie v. Stategreen
texapp · 1991 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Appellant failed to preserve error 8 PRAYER FOR RELIEF 8 CERTIFICATE OF SERVICE 9 CERTIFICATE OF WORD COUNT 9 3 INDEX OF AUTHORITIES Cases Archie v. State, 799 S.W.2d 340, 344 (Tex. App.—Houston [14th Dist.] 1990) .....7 Burgess v. State, 816 S.W.2d 424 (Tex. Crim.

11
Batson v. Kentuckygreen
scotus · 1986 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010See Batson, 476 U.S. at 106 ; see also Mathis v. State, 67 S.W.3d. 918, 924 (Tex. Crim.

11
United States v. Reevesgreen
waed · 1992 · cited in 1 Texas opinions naming this issue, 1995–1995
2 sentences

1995See United States v. Reeves, 798 F.Supp. 1459, 1464 (E.D.Wash.1992) (objective approach “effectively eliminate^] the pretext rule”).

1995See United States v. Reeves, 798 F.Supp. 1459, 1464 (E.D.Wash.1992) (objective approach "effectively eliminate[s] the pretext rule").

11
Lyon v. Stategreen
texcrimapp · 1994 · cited in 1 Texas opinions naming this issue, 1995–1995
2 sentences

1995The cases discussing the pretext doctrine, or cited by this Court as support for the pretext doctrine, are legion. 3 After reviewing these cases, however, we are forced to admit, as Presiding Judge McCormick opined recently in a different context, that our efforts in this area have failed as “a model of clarity and concise legal analysis.” Lyon v. State, 872 S.W.2d 732, 734 (Tex.Cr.

1995The cases discussing the pretext doctrine, or cited by this Court as support for the pretext doctrine, are legion. [3] After reviewing these cases, however, we are forced to admit, as Presiding Judge McCormick opined recently in a different context, that our efforts in this area have failed as "a model of clarity and concise legal analysis." Lyon v. State, 872 S.W.2d 732, 734 (Tex.Cr.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Gross v. FBL Financial Services, Inc. green
scotus · 2009
2 sentences

2011Gross, 129 S.Ct. at 2349 n. 2.

2011Gross, 129 S. Ct. at 2349 n.2.

22011–2011
Quantum Chemical Corp. v. Toennies green
tex · 2001
2 sentences

2004Rather, it held that plaintiffs can prove discrimination was a “motivating factor” for the employment decision by showing that the employer’s articulated reason was mere pretext. 47 S.W.3d at 481-82 .

2004Rather, it held that plaintiffs can prove discrimination was a "motivating factor" for the employment decision by showing that the employer's articulated reason was mere pretext. 47 S.W.3d at 481-82 .

22004–2004
Kanida v. Gulf Coast Medical Personnel LP green
ca5 · 2004
1 sentence

2026See FIFTH CIRCUIT PATTERN JURY INSTRUCTIONS (Civil) No. 11.5 (2020) (Title VII retaliation); id.

12026–2026
Burgess v. State green
texcrimapp · 1991
1 sentence

2015Appellant failed to preserve error 8 PRAYER FOR RELIEF 8 CERTIFICATE OF SERVICE 9 CERTIFICATE OF WORD COUNT 9 3 INDEX OF AUTHORITIES Cases Archie v. State, 799 S.W.2d 340, 344 (Tex. App.—Houston [14th Dist.] 1990) .....7 Burgess v. State, 816 S.W.2d 424 (Tex. Crim.

12015–2015
Whren v. United States green
scotus · 1996
2 sentences

2001Thus, the Court reasoned that a traffic stop based on an observation of a traffic offense “foreclose[d] any argument that the constitutional reasonableness of traffic stops depends on the actual motivations of the individual officers involved” or whether “the officer’s conduct deviated materially from usual police practices, so that a reasonable officer in the same circumstances would not have made the stop for the reasons given.” Id. at 813 , 116 S.Ct. 1769 .

2001Thus, the Court reasoned that a traffic stop based on an observation of a traffic offense “foreclose[d] any argument that the constitutional reasonableness of traffic stops depends on the actual motivations of the individual officers involved” or whether “the officer’s conduct deviated materially from usual police practices, so that a reasonable officer in the same circumstances would not have made the stop for the reasons given.” Id. at 813 , 116 S.Ct. 1769 .

12001–2001
Crittenden v. State green
texcrimapp · 1995
1 sentence

1995In both Garcia v. State, 827 S.W.2d 937 (Tex.Crim.App.1992) and Crittenden v. State, 899 S.W.2d 668 (Tex.Crim.App.1995), the Texas Court of Criminal Appeals was presented with challenges to the admissibility of evidence obtained as the result of alleged “pretext arrests.” Each case arose out of stops made as the result of a traffic offense.

11995–1995
United States v. Lefkowitz green
scotus · 1932
2 sentences

1990The origin of the doctrine or theory is generally accorded the Supreme Court decision in United States v. Lefkowitz, 285 U.S. 452 , 52 S.Ct. 420 , 76 L.Ed. 877 (1932).

1990The origin of the doctrine or theory is generally accorded the Supreme Court decision in United States v. Lefkowitz, 285 U.S. 452 , 52 S.Ct. 420 , 76 L.Ed. 877 (1932).

11990–1990

Statutes the citing opinions construe

TX § Tex. Lab. Code § 21.051 (7) TX § Tex. Lab. Code § 21.055 (6) TX § Tex. Lab. Code § 21.125 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 22 (1990–2026) UT 16 (1992–2019) WA 15 (1992–2019) IA 9 (1994–2020) IL 7 (1991–2025) KS 6 (1994–2023) CA 6 (1999–2025) NM 5 (1990–2016) NY 4 (1993–2024) IN 4 (1995–2025) PA 4 (2010–2018) CT 4 (2000–2015) AK 4 (2001–2019) NJ 4 (2005–2024) FL 4 (1993–2023) AR 3 (2002–2010) MO 3 (1958–2013) NV 3 (1995–2016) MA 3 (1995–2026) MS 2 (1916–1930) TN 2 (2010–2017) CO 2 (1995–1996) DC 2 (2010–2012) HI 2 (2008–2010) MD 2 (2022–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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