Pruitt v. Int'l Ass'n. of Fire Fighters

In Pruitt v. Int'l Ass'n. of Fire Fighters, 366 S.W.3d 740 (Tex. App.--Texarkana 2012, no pet.), Michael Pruitt filed suit against the International Association of Fire Fighters labor union, a local affiliate association, and the certain officers and directors of the local association, after his employment was terminated. 366 S.W.3d at 742. Pruitt was the first African-American Fire Chief in Longview, Texas. Id. Pruitt alleged causes of action for "intentionally aiding or abetting discrimination," intentional infliction of emotional distress, . . . breach of fiduciary duty, and tortious interference with employment relations." Id. Pruitt's claims were dismissed for lack of subject matter jurisdiction. Id. The trial court ruled, in part, that Pruitt's common-law claims were pre-empted by Chapter 21. Id. Pruitt appealed and argued that the trial court erred in dismissing his claims of intentional infliction of emotional distress, breach of fiduciary duty, and tortious interference with employment relationship and that, as an alternative to dismissal, the trial court should have allowed him to amend the complaint by removing references to the alleged discrimination. Id. at 742, 747. The Texarkana Court of Appeals concluded that the facts giving rise to Pruitt's common-law causes of action were "inextricably intertwined" with the facts giving rise to complaints that could have been resolved through Chapter 21's administrative procedures. Id. at 749-50. The Court stated that "a racial discrimination complaint was the gravamen of Pruitt's action and that allowing his complaint to proceed without meeting the requirement of exhaustion of remedies would 'collide with the elaborately crafted statutory scheme.'" Id. at 750.