Lauralee Richmond v. Team One Contract Services, L.L.C., d/b/a TeamOne Logistics

Houston, Employment law lawyer represented the Plaintiff who sued on a pregnancy discrimination civil rights violation theory.



Richmond began working for TeamOne in 2019 as an Operations Manager at the company's Freeport, Texas location. TeamOne had a contract with UPS Logistics and was responsible for hiring and managing truck drivers for a UPS client's Freeport facility. For her part, Richmon directly managed and supervised a fleet of truck drivers and support staff. One of Richmond's primary responsibilities was ensuring compliance with safety protocol. She was tasked with conducting weekly driver observations and monthly "Comprehensive Health and Safety Process” meetings, as well as participating in weekly "Safety Action Plan” and quarterly safety meetings with TeamOne's corporate Safety Department. She was also required to submit safety meeting and observation reports—using specific forms—to the UPS National Account Manager.



In early 2020, TeamOne started tracking drivers' "hard brakes.”1 Richmond was then tasked with reviewing weekly hard-brake reports, coaching drivers with multiple hard brakes in one week, and documenting that coaching session. If a driver had frequent hard brakes throughout the month, Richmond would conduct "face-to-face counseling” and give a "re-

training session.” This session would be documented in the driver's personnel file.



Richmond later notified TeamOne's Human Resources Generalist that she was pregnant and told the Vice President of Human Resources that she would "be out for 12-15 weeks” on maternity leave. Complaints against Richmond piled up over subsequent months. For example, the UPS Division Driver Trainer complained about her responsiveness. Richmond had allegedly proven unwilling to coordinate a hard-brake counseling and re-training session, and she had not responded to

his plea for help in training drivers with multiple hours-of-service violations. TeamOne's Director of Safety and Compliance complained that "not one single coaching document or discipline document has been turned in”— despite requesting for months that Richmond submit them. On this score, TeamOne disciplined Richmond. The company had

"been tracking hard brakes since May and as of [November 20, 2020] [had] not received a single coaching document.” A "total of 65 counseling documents” were missing. Richmond was told to submit all missing documentation within a few days.



In response, Richmond insisted that she knew better—TeamOne's "disciplinary approach to documentation” did not work, and she had "the number one ranked terminal in UPS.” She added that she would either need to "perjure [her]self by forging documentation” or "continue to raise objection” against TeamOne's documentation policy. She then reminded the company that she was pregnant and would take leave. At this point, she rejected the Vice President of Human Resources's alleged suggestion that she work from home after delivering the baby.



More complaints piled up in following weeks—these perhaps more serious than before. The UPS Division Driver Trainer highlighted the number of hours-of-service violations at Richmond's site. He also flagged inaccurate driver logs: "If these log violation[s] were discovered in a [Department of Transportation] audit or during inspection,” UPS would be

hit with 51 Compliance, Safety, and Accountability points.



By early March 2021, TeamOne began preparing for Richmond to take maternity leave by training other employees to cover her workload. At that point, TeamOne's Transportation Supervisor revealed that Richmond (1) never conducted monthly Comprehensive Health and Safety Process meetings, (2) asked a TeamOne employee to falsely pay a driver, (3) was

rarely in the office, and more.



Richmond was fired a few days later. Cited reasons include "falsifying safety documents regarding driver observations and failing to follow paperwork protocol surrounding driver observations and safety meeting[s].”

She was seven months pregnant.



This pregnancy discrimination suit followed.

The district court granted summary judgment to TeamOne, because Richmond could not establish that TeamOne’s cited reasons for termination were pretextual.

Richmond appealed.'



Affirmed