Fields v. Teamsters Local Union No. 988

Appellant Maria Fields brought suit under two sections of the Texas Labor Code: section 21.051 prohibits sexual harassment and gender discrimination by an “employer,” and section 21.055 prohibits retaliation by an “employer” or a labor union against a person who files a complaint under chapter 21. Appellant also sued for intentional infliction of emotional distress.

The majority opinion affirms summary judgment for the labor union as to the cause of action under section 21.051 of the Texas Labor Code. I dissent from this holding because the summary judgment evidence raises a fact issue about…