4 Elements of Claims requiring Relief

U.S. District Court 

Northern District of Texas (Dallas) 

Willie Lee HavMmeri,

Plaintiff

vs.

Methodist Health Systems,

Defendant

Case No. 3:22-cv-00594-E-BT

Assigned Judge: Ada Brown

Magistrate Judge: Rebecca Rutherford

Defendant’s Legal Team: Ogletree Deakins Nash Smoak & Stewart PC

(Employment Law Firm – Dallas, Texas)

Cause: 42:1983 Civil Rights (Employment Discrimination)

Nature of Suit: 442 Civil Rights: Employment

Date Filed: 03/14/2022

Today’s Date: 05/06/2023

Overview

Before the Court is the case of Willie Lee HavMmeri (Plaintiff) vs Methodist Health Systems (Defendant) 

as it relates to Wrongful Termination, Due to Retaliation and Gender Discrimination. Below I shall detail 

my understanding of the Four Elements of a Claim, by which Relief may be granted. I believe that I am 

able to prove these four elements of a claim with each of my Four Claims (Listed in Doc. 65).

[Summary of Claims are in green font]

Four Elements of a Claim

a. Duty of Care – Defendant’s responsibility to protect Plaintiff from harm.

b. Breach of Care – Defendant’s failure to protect Plaintiff

c. Causation – What was the result of this failure to protect Plaintiff

d. Damages – What does the Plaintiff demand as compensation for pain/suffering/mental 

anguish/loss

Claim One: Wrongful Termination for the Narrative regarding Manipulation of Financial Documents.

Claim Two: Wrongful Termination, due to Retaliation

Claim Three: Wrongful Termination, due to Gender Discrimination

Claim Four: Wrongful Termination, resulting in loss of full-time employment

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Claim 1: Wrongful Termination for the Narrative regarding Manipulation of Financial Documents.

1a. Duty of Care

Methodist Health Systems (Defendant), cited “Manipulation of Financial Documents” as the “Immediate 

Terminable Offenses” listed on the Termination Letter. (Amended Complaint – Doc. 24). While I agree 

that manipulating financial documents is, in fact, an immediate terminable offense as outlined in 

Company Policy (Doc. 24), the Defendant first had the Duty of Care to inform me that I was being 

investigated for said offenses and allow me to give evidence to the contrary, for consideration. This did 

not occur. Furthermore, the Defendant did not follow it’s own policy, which outlines “Suspension, 

Pending Investigation & Review” (Doc. 24). 

1b. Breach of Care

By not affording me the opportunity to defend myself before the termination letter was written and 

delivered to me to acknowledge on April 10th 2020, the Defendant was in Breach of their Duty of Care in 

such matters of establishing an immediate terminable offense. 

1c. Causation

The Defendant’s Breach of their Duty of Care owed to me as an employee resulted in me being informed 

I was being fired, on the day I was fired. The defendant made no effort to ensure I was aware of 

immediate terminable offenses before the termination date. 

1d. Damages

By the Defendant terminating my employment for manipulating financial documents, it has rendered me 

unemployable in my field of expertise. This has caused me much suffering to which I have asked for 

damages, outlined in Document 65 of this case. 

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Claim 2: Wrongful Termination, due to Retaliation

2a. Duty of Care

The Defendant failed to consider my Formal Complaint regarding Working Environment, delivered to my 

immediate supervisor on March 17th 2020, via email. While I adhered to the Defendant’s “Chain of 

Command” Policy (Doc. 24), this policy did not protect me from retaliatory measures by my immediate 

supervisor. 

2b. Breach of Care

Rather than the Defendant acknowledging the unfortunate breakdown within protocol as a result of me 

submitting a complaint in good faith to my immediate supervisor which implicated the immediate 

supervisor, the Defendant has decided to ignore the subject matter of my formal complaint and dismiss 

it in it’s entirety as “a co-worker being a little rude”. (Doc 33). 

2c. Causation

Failing to consider my Formal Complaint before terminating employment 24 days later, resulted in a 

Breach of Care, to which I as an employee of the Defendant was entitled to. State Laws have been cited 

that state it is against the law for an employer to terminate the employment of an employee prior to 60 

days after a complaint made in good faith (Doc. 24). Despite the evidence to the contrary, the Defendant 

has maintained in numerous statements delivered to the EEOC, TWC and US District Courts that there 

was no retaliation regarding my termination for the narrative of manipulating financial documents. This 

retaliation led to my termination of employment which was outlined in Claim One. 

2d. Damages

By failing to consider my Formal Complaint delivered on March 17th 2020, the Defendant allowed me to 

be removed from the workplace, before my complaint was address in accordance with their Company 

Policy, which outlines how I am to be protected during the process (Doc. 24). This has caused me much 

suffering to which I have asked for damages, outlined in Document 65 of this case. 

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Claim 3: Wrongful Termination, due to Gender Discrimination

3a. Duty of Care

Laws are in place to insure that employees are not discriminated against based on gender, amongst 

other characteristics. It is the Responsibility/ Duty of Care of the Defendant to see to it that 

Departments and staff are aware of this fact. I believe the Defendant, in it’s Company Policy, did an 

adequate job of outlining this fact. 

3b. Breach of Care

While the Defendant’s Company Policy does in fact outline Discrimination based on Gender as illegal, the 

Defendant did nothing to provide me with the means of having such a claim, whether deemed 

outlandish or otherwise, investigated objectively and fairly. For example, the Defendant’s Policy outlines 

the employee who makes such a claim is to fill out an Incident Report, complete with the employee’s

grievances listed and signature. This did not occur. There has still not been a request for such an 

Incident Report and the position of the Defendant is that my claims related to the consequences of 

workplace violence based on gender, preferential treatment based on gender and hourly allotment 

based on gender were non-existent. 

3c. Causation

The Defendant’s failure or Breach of Care with regard to allowing me to voice my concerns for 

investigating Gender Discrimination through the Company’s Policy (Incident Report) allowed my 

immediate supervisor the discretion to orchestrate my removal from the work environment with the 

help of Human Resources. 

3d. Damages

By failing to adhere to their own Company Policy regarding Incident Reports, the Defendant allowed for 

my removal from the work environment based on a narrative of manipulating financial documents, as a 

retaliatory measure. My formal complaint detailing Gender Discrimination, delivered in good faith to the 

Defendant was never addressed. The Defendant’s only position on the subject delivered to the Court to 

date is “a co-worker was a little rude to the Plaintiff”. I find such a position as insulting as it is dismissive. 

This has caused me much suffering to which I have asked for damages, outlined in Document 65 of this 

case. 

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Claim 4: Wrongful Termination, resulting in loss of full-time employment

4a. Duty of Care

The Defendant had a Duty of Care to see to it that I was investigated properly. The Defendant had a Duty 

of Care to ensure the Company was not liable for retaliation by confirming I had no active complaints 

against the company on record *within* 60 days of the termination. The Defendant had a Duty of Care 

to conclude an investigation into Gender Discrimination in the Cardiology Department prior to opening 

an investigation into me as an employee, with the potential to be terminated. 

4b. Breach of Care

The Breaches of Care outlined in Claims One, Two and Three each would be suitable to establish a 

Breach of Care with regard to this Claim four. 

4c. Causation

Wrongful Termination because of claims One, Two and Three caused this Fourth Claim. Were it not for 

the Breaches of Care listed in Claims One, Two and Three I would still enjoy full-time employment and 

the benefits associated with such. Should any one claim mentioned above be proven true in a court of 

law, this Claim Four serves as an unfortunate byproduct. Had I never complained to the Defendant on 

March 17th 2020, I would not have been investigated on March 29th of 2020 and ultimately fired on April 

10th of 2020. 

4d. Damages

This has caused me much suffering to which I have asked for damages, in the form of back wages and 

continued pay, amongst other full-time employee benefits, as outlined in Document 65 of this case. 

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Civil Concession for the sake of the Defendant

I, Willie Lee HavMmeri (Plaintiff), would like to acknowledge that any and all Miscellaneous Relief 

Requested, Ordered and Paid by the Defendant shall be subtracted/deducted from the Damages section 

of Claim Four (4), as outlined in Document 65 of this case. This is a gesture of goodwill to the Company, 

to which I had the pleasure of working for 6 years with the hopes that all parties can end this matter 

amicably. 

I would like to remind the Court, again, that according to the Texas Health and Safety Code – Section 

161.134:

(a) A hospital, mental health facility, or treatment facility may not suspend or terminate the 

employment of or discipline or otherwise discriminate against an employee for reporting to the 

employee's supervisor, an administrator of the facility, a state regulatory agency, or a law 

enforcement agency a violation of law, including a violation of this chapter, a rule adopted under 

this chapter, or a rule of another agency.

(b) A hospital, mental health facility, or treatment facility that violates Subsection (a) is liable to 

the person discriminated against. A person who has been discriminated against in violation of 

Subsection (a) may sue for injunctive relief, damages, or both.

(f) A plaintiff suing under this section has the burden of proof, except that it is a rebuttable 

presumption that the plaintiff's employment was suspended or terminated, or that the employee 

was disciplined or discriminated against, for making a report related to a violation if the 

suspension, termination, discipline, or discrimination occurs before the 60th day after the date 

on which the plaintiff made a report in good faith.

(h) A person who alleges a violation of Subsection (a) must sue under this section before the 

180th day after the date the alleged violation occurred or was discovered by the employee 

through the use of reasonable diligence.

I implore the court to consider any and all Miscellaneous Relief as Injunctive, by the standards laid out in 

the Texas Health and Safety Code – Section 161.134

I declare that my actions were protected under Title VII of the Civil Rights Act of 1964 and that the 

actions of the Defendant were in direct violation of said Law, amongst others listed in the Amended 

Complaint (Doc. 24). 

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Conclusion 

My termination was WRONGFUL. It was RETALIATION for questioning an unfair bias, due to GENDER.

I am more than a name in the PLAINTIFF section of documents. 

Please consider any and all request for Miscellaneous Relief as an INJUNCTION (Document 63). 

Respectfully submitted, 

May 6th, 2023 

By: _____/s/ Willie HavMmeri_________

Willie Lee HavMmeri, self-represented “Pro se”

godcolored@gmail.com

(214) 600-6207

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