Jackson v. Univ. of Texas M.D. Anderson Cancer Ctr.,
No. H-00-0531 (S.D. Tex. Oct. 30, 2001)

A physician sued her former employer, a university, for breach of contract, constructive discharge, and racial discrimination under Title VII. When the physician began employment at the university as director of a new surgery unit, she discovered that the terms of her contract were different from the terms discussed at the interview, most notably the starting salary, the length of the contract, and the physician's ability to engage in private practice outside the university. Only some of these provisions were later amended to be brought into line with the physician's expectations. The physician also complained that she was slighted throughout the course of her employment by being given less support from residents, secretaries, and histotechnicians than other faculty members. The university moved for summary judgment.

The United States District Court, Southern District of Texas, granted the university's motion for summary judgment. The court held that a claim for constructive discharge must show that the employer created an intolerable work condition which would cause any reasonable employee to feel compelled to resign. The court found the physician had not made such a showing. Additionally, the court ruled that the physician had failed to produce any evidence to show that the university's explanations for its actions were false or that racial animus was the motivation for any of its actions.