Garcia v. Garland Independent School District

Maria Garcia (plaintiff), a Hispanic woman, worked as a cook at a high school in Garland Independent School District (GISD) (defendant). Garcia sued GISD, alleging that it violated Title VII of the Civil Rights Act of 1964 by subjecting Garcia to a hostile work environment based on her national origin. Specifically, Garcia alleged that her coworkers and her supervisor, Patricia Anderson, regularly made fun of Garcia’s accent and her inability to pronounce certain English words and referred to her as dumb and a crybaby. Garcia also presented evidence that despite GISD’s policy against limiting the use of any language except for safety purposes, Anderson advised her employees that they were not permitted to speak any Spanish in her kitchen during work hours. Finally, Garcia alleged that she received a heavier workload and less desirable assignments than non-Hispanic colleagues. GISD moved for summary judgment, arguing that Garcia had failed to make a prima facie case demonstrating a hostile work environment. Specifically, GISD argued that Garcia could not attribute the alleged different workload, jokes about mispronunciation, and prohibition on Spanish to her national origin. Additionally, being called dumb or a crybaby did not relate to Garcia being Hispanic. The court considered whether to grant GISD’s motion for summary judgment.