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Nancy Honea sued SGS Control Services, Inc., her former employer, alleging disparate treatment and sexual harassment under Title VII, as well as state law claims for intentional and negligent infliction of emotional distress. Honea was terminated after an alleged performance error. The court denied SGS's motion for summary judgment on the Title VII claims, finding genuine issues of material fact regarding pretext for discrimination and whether the harassment was reported and unwelcome. However, the court granted summary judgment for SGS on the emotional distress claims, stating the conduct did not meet the 'extreme and outrageous' standard for intentional infliction and Texas law does not recognize negligent infliction of emotional distress as an independent claim. The court also granted SGS's motions to strike Honea's jury demand and claim for punitive damages, citing that the 1991 Civil Rights Act amendments do not apply retroactively to conduct occurring prior to its effective date.
Honea v. SGS Control Services Inc. is a workers' compensation case decided in District Court, E.D. Texas. This case addresses legal issues related to compensation claims, benefits, and court rulings.
It is commonly referenced in legal research involving workers' compensation laws in District Court, E.D. Texas.
Full Decision Text1 Pages
Nancy Honea sued SGS Control Services, Inc., her former employer, alleging disparate treatment and sexual harassment under Title VII, as well as state law claims for intentional and negligent infliction of emotional distress. Honea was terminated after an alleged performance error. The court denied SGS's motion for summary judgment on the Title VII claims, finding genuine issues of material fact regarding pretext for discrimination and whether the harassment was reported and unwelcome. However, the court granted summary judgment for SGS on the emotional distress claims, stating the conduct did not meet the 'extreme and outrageous' standard for intentional infliction and Texas law does not recognize negligent infliction of emotional distress as an independent claim. The court also granted SGS's motions to strike Honea's jury demand and claim for punitive damages, citing that the 1991 Civil Rights Act amendments do not apply retroactively to conduct occurring prior to its effective date.
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