Vasquez v. Bannworths, Inc.
Texas Supreme Court
707 S.W.2d 886 (1986)
Farm worker Maria Vasquez (plaintiff), employed by Bannworths, Inc. (defendant) since 1973, joined the United Farm Workers (UFW) union and reported Bannworths' poor employee working conditions — including a shared drinking cup and unsanitary portable bathrooms — to the union, prompting a county health inspection; Bannworths fired her that same day. Vasquez sued alleging discrimination for her UFW membership under the Texas Right-to-Work Act, seeking lost-wage damages and an injunction ordering her reinstatement and barring future violations; the jury found she was fired for her union membership and would continue to be injured absent relief, awarding $3,000 in lost wages. The trial judge, while finding irreparable injury without an adequate legal remedy, enjoined future discrimination against Vasquez but declined to order her actual reinstatement, instead conditioning the injunction on Bannworths' voluntary rehiring; Vasquez appealed the failure to order reinstatement, and the court of appeals affirmed.
Whether a trial court's discretion in fashioning injunctive relief for violations of a state employment statute is limited by the requirement that the remedy effectuate the policies of, and undo the effects of violations of, the statute.