DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

NATHANIEL KING §

§

Plaintiff, §

§

v. § CIVIL ACTION NO. 4:22-CV-929-P

§

§

DALLAS-FORT WORTH §

INTERNATIONAL AIRPORT BOARD, §

§

Defendant. §

DEFENDANT DALLAS-FORT WORTH

INTERNATIONAL AIRPORT BOARD’S

MOTION FOR SUMMARY JUDGMENT

TO THE HONORABLE COURT:

Defendant, Dallas-Fort Worth International Airport Board (“DFW”), moves for an order 

granting summary judgment against Plaintiff Nathaniel King (“Plaintiff”) pursuant to Federal Rule 

of Civil Procedure 56. 

1. DFW is entitled to summary judgment on Plaintiff’s disability discrimination claim

because Plaintiff is not a qualified individual. 

2. Even if Plaintiff could establish that he was a qualified individual, DFW is still 

entitled to summary judgment on Plaintiff’s disability discrimination claim because Plaintiff 

cannot establish a causal connection between his disability and any alleged adverse employment 

action. 

3. Plaintiff’s disability discrimination claim also fails to the extent Plaintiff claims 

DFW allegedly refusing to reassign him constitutes an adverse employment action.

Case 4:22-cv-00929-P Document 20 Filed 06/09/23 Page 1 of 4 PageID 480
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 2

4. DFW is entitled to summary judgment on Plaintiff’s retaliation claim because 

Plaintiff cannot establish a causal connection between his request for accommodation and his 

administrative termination.

5. Additionally, DFW is entitled to summary judgment on Plaintiff’s retaliation claim 

because Plaintiff cannot establish a causal connection between his request for accommodation and 

DFW’s alleged refusal to reassign him.

6. Plaintiff’s retaliation claim also fails to the extent Plaintiff claims DFW allegedly 

refusing to reassign him constitutes an adverse employment action.

7. Finally, DFW is entitled to summary judgment on Plaintiff’s discrimination and 

retaliation claims because DFW has articulated a legitimate nondiscriminatory, nonretaliatory 

reason for Plaintiff’s administrative termination and Plaintiff cannot sustain his ultimate burden of 

proof to show DFW’s reason for terminating him was pretextual.

8. This Motion is based on the attached Brief in Support of Motion for Summary 

Judgment, the attached summary judgment evidence, and all pleadings and papers on file.

PRAYER

WHEREFORE, PREMISES CONSIDERED, DFW respectfully requests that the 

Court grant its Motion for Summary Judgment, that Plaintiff’s lawsuit be dismissed in its entirety, 

that the Court award DFW its costs, and that DFW be given all other relief to which it is justly 

entitled.

Case 4:22-cv-00929-P Document 20 Filed 06/09/23 Page 2 of 4 PageID 481
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 3

Respectfully submitted,

By: /s/ Caroline C. Harrison

Caroline C. Harrison 

State Bar No. 24046034

charrison@phamharrison.com

Spencer M. Mainka

State Bar No. 24116707

smainka@phamharrison.com

PHAM HARRISON, LLP

505 Pecan Street, Suite 200

Fort Worth, Texas 76102

(817) 632-6300

(817) 632-6313 – Fax

ATTORNEYS FOR DEFENDANT

Case 4:22-cv-00929-P Document 20 Filed 06/09/23 Page 3 of 4 PageID 482
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 4

CERTIFICATE OF SERVICE

The undersigned hereby acknowledges that a true and correct copy of the above-mentioned 

document was served in accordance with the Federal Rules of Civil Procedure on this the 9th day 

of June, 2023 on counsel for Plaintiff as follows:

Wes Dauphinot 

Law Offices of Wes Dauphinot, P.C.

900 West Abram

Arlington, Texas 76103

wes@dauphinotlawfirm.com

Hani F. Kobty

Kobty Law Firm

900 West Abram

Arlington, Texas 76103

hani@kotbylawfirm.com

ATTORNEYS FOR PLAINTIFF

/s/ Caroline C. Harrison

Caroline C. Harrison

Case 4:22-cv-00929-P Document 20 Filed 06/09/23 Page 4 of 4 PageID 483