## Facts

- Eduardo Machado, a Cuban employee, worked for Goodman Manufacturing Company, L.P. for about four years as Regional Sales Manager for Mexico, Latin America, and the Caribbean, working from Miami, Florida.
- During his Miami tenure, Machado reported no discriminatory comments or conduct connected to his employment.
- In March 1995, Goodman selected Machado to serve as Vice President of International Sales and required him to relocate to Houston, Texas.
- Machado alleged that the company paid him less than the outgoing vice president and assigned him an inferior office upon taking the vice-president role.
- After relocating to Houston, Machado claimed he began experiencing national-origin harassment, including comments by another vice president, Barry Watson, stating on multiple occasions that he did not want “Cubans” living in his neighborhood.
- Machado also alleged that Goodman executives interfered with his ability to perform the vice-president job by limiting or diminishing his authority in international dealings.
- As part of that claim, Machado asserted that, before an overseas trip, a vice president (Peter Alexander) told him to act as though he had no knowledge and to return with information for others to evaluate.
- Machado further alleged that, during a trip to Thailand, a business contact told him it had received a call indicating Machado lacked authority to make decisions and that he was only there to view equipment and gather brochures.
- Roughly two months after starting in Houston, Machado resigned, citing discriminatory remarks and treatment.
- Goodman’s President and CEO, Thomas Burkett, persuaded Machado to stay, investigated Watson’s remarks, and warned Watson that continued conduct could lead to termination.
- Watson allegedly continued the same type of remarks and behavior after the warning.
- After about three months in the new role, Machado asked Burkett for permission to return to Miami and perform the vice-president job from his home office; Burkett agreed.
- After Machado returned to Miami, Burkett placed Watson in Machado’s supervisory chain despite Machado’s prior complaints about Watson.
- Machado alleged Watson’s conduct continued and that, when Machado again complained to Burkett, the complaints were not treated seriously.
- Machado resigned about two months later and filed suit against Goodman Manufacturing Company, L.P. and Goodman Holding Company, asserting Title VII national-origin discrimination in the form of a hostile work environment and asserting constructive discharge.
- Defendants moved for summary judgment and also moved to strike materials Machado filed in connection with the summary-judgment briefing.

## Issues

1. Whether Machado produced sufficient evidence for a reasonable jury to find a hostile work environment based on national origin under Title VII.
2. Whether the evidence was sufficient to establish constructive discharge—i.e., working conditions so intolerable that a reasonable person would feel forced to resign.
3. Whether Goodman could be held responsible for alleged harassment in light of what management knew and what remedial steps were taken after complaints.
4. Whether materials filed by Machado in connection with summary judgment should be struck.

## Decision

- The court granted defendants’ motion to strike Machado’s notice of filing and attached documents.
- The court granted in part and denied in part defendants’ motion for summary judgment.
- The court denied summary judgment on Machado’s Title VII hostile-work-environment theory, holding that the record contained fact disputes a jury could resolve in Machado’s favor on harassment based on Cuban national origin.
- The court granted summary judgment for defendants on Machado’s constructive-discharge claim, concluding the evidence did not meet the objective “forced to resign” standard.

## Legal Principles

- A Title VII hostile-work-environment claim requires evidence that: (1) the plaintiff belongs to a protected class; (2) the plaintiff was subjected to unwelcome harassment; (3) the harassment was because of the protected trait (here, national origin); (4) the harassment affected a term, condition, or privilege of employment by being sufficiently severe or pervasive; and (5) a basis exists to hold the employer responsible.
- Harassment may include both verbal comments and workplace conduct; the factfinder considers the totality of circumstances (frequency, severity, whether it is threatening or humiliating, and whether it interferes with work).
- Employer responsibility depends on the source of the harassment and what the employer knew or should have known; prompt and effective remedial action can limit or defeat liability.
- Constructive discharge requires more than a hostile environment; the plaintiff must show objectively intolerable conditions such that a reasonable employee would feel compelled to resign.
- On summary judgment, the court does not decide credibility disputes and must view the evidence in the nonmovant’s favor; summary judgment is proper only when there is no genuine dispute of material fact.
- A court may strike summary-judgment materials that are improper for consideration under the governing rules and procedures.

## Conclusion

Machado v. Goodman Manufacturing Co. held that Machado presented enough evidence—such as repeated anti-Cuban remarks and alleged interference with his authority—to require a jury trial on a Title VII hostile work environment claim, but the court rejected constructive discharge as a matter of law and struck certain materials filed by Machado in the summary-judgment record.


Machado v. Goodman Manufacturing Co., 10 F. Supp. 2d 709 (1997)