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Carter v. Gulf Oil Corp.

Citations: 699 S.W.2d 907; 1985 Tex. App. LEXIS 12685Docket: 09 85 022 CV

Court: Court of Appeals of Texas; September 26, 1985; Texas; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a plaintiff against a summary judgment in favor of Gulf Oil Corporation, concerning her claim of discrimination as a 'handicapped person' under Texas law. The plaintiff, whose vision did not meet the company's standards for a Maintenance Helper position, argued that Gulf Oil violated statutory provisions against discrimination. The trial court found that she did not meet the statutory definition of 'handicapped,' and thus Gulf Oil owed no duty to her. Both parties sought a judicial interpretation of the term 'handicapped person,' due to ambiguities in the legislative definition. The court examined the statutory framework, emphasizing the prohibition against employment discrimination based on handicap unless it constitutes a bona fide occupational qualification necessary for the job. The appellate court determined that the trial court erred in granting summary judgment, as the necessity of Gulf Oil's visual requirement as a bona fide occupational qualification was a factual issue needing trial. Consequently, the summary judgment was reversed, and the matter was remanded for further proceedings to explore whether the visual standard was justifiably a bona fide occupational qualification.

Legal Issues Addressed

Ambiguity in Legislative Definitions

Application: Both parties requested judicial clarification of the term 'handicapped person' due to the perceived circularity in the legislative definition.

Reasoning: Both parties request the court to establish a 'judicial' definition of 'handicapped person,' arguing that the legislative definition is circular, using the term 'handicapped' to define itself.

Bona Fide Occupational Qualification

Application: The court remanded the case for trial to examine whether Gulf Oil's visual standard was a bona fide occupational qualification.

Reasoning: The court could not legally conclude that Gulf Oil's visual requirement qualifies as a bona fide occupational qualification, indicating that this issue is factual and requires further examination.

Definition of 'Handicapped Person' under Texas Law

Application: The court examined the statutory definition of 'handicapped person' to determine if the plaintiff met the criteria, ultimately concluding that she did not.

Reasoning: The trial court concluded that Carter did not meet the legal definition of a 'handicapped person' and therefore Gulf Oil owed her no duty under the law.

Discrimination in Employment under Texas Law

Application: The court highlighted that the statute prohibits employment discrimination based on handicap unless it is a bona fide occupational qualification.

Reasoning: Section 5.01 outlines that it is unlawful for an employer to discriminate against individuals based on race, color, handicap, and other factors.