School Employee Failed to State Sufficient Facts to Support Suit; Allowed to Amend

Fernando Yates sued his former employer, Spring Independent School District (Spring ISD), for employment discrimination and retaliation under the Age Discrimination and Employment Act. He alleged demotion, reassignment to menial tasks, and harassment, claiming these actions led to his resignation in June 2023, which he characterized as constructive discharge. Yates’s initial lawsuit (“Yates 1”) with similar allegations had already been dismissed and was on appeal. The present lawsuit reiterated these claims and added the constructive discharge claim.

Spring ISD filed a motion to dismiss, which the court granted. The court found that Yates’s new lawsuit raised issues already litigated in Yates 1, thus invoking the doctrines of res judicata and collateral estoppel, preventing re-litigation of the same claims. The court also found Yates’s constructive discharge claim insufficient, as he did not present specific allegations of intolerable working conditions at Bailey Middle School, where he worked after the alleged discrimination at Spring Leadership Academy. Yates was given 30 days to amend his complaint to specify acts at Bailey that could substantiate his constructive discharge claim.

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