A Texas appellate court has ruled that an employment dispute involving a former occupational therapy assistant must be resolved through arbitration. The decision affects Patricia Burns, who alleged she was wrongfully terminated after raising concerns about patient treatment at Reliant Pro Rehab, LLC. The court's ruling emphasizes the importance of arbitration agreements in employment contracts.
The case, Reliant Pro Rehab, LLC., Touchstone Communities, Inc., Touchstone Strategies - NW Houston, LLC., Touchstone Realty - NW Houston, LLC, Liberty County Hospital District No. 1, Brian Martin, Loretta Rowe, and Michelle Chen v. Patricia Burns, was filed in the Texas Court of Appeals, 1st District, with the docket number 01-24-00518-CV. The court issued its opinion on June 16, 2026, reversing a lower court's decision that denied the motion to compel arbitration.
Background
Patricia Burns worked as an occupational therapy assistant at Reliant Pro Rehab. She claimed that her termination was retaliatory, occurring after she reported concerns regarding the treatment of a patient. Burns filed a lawsuit against Reliant and several associated parties, alleging that her firing violated the Texas Health and Safety Code.
The defendants, including Reliant and its associated entities, sought to compel arbitration based on an arbitration agreement that Burns had signed as part of her employment. They argued that her claims fell within the scope of this agreement, which required that employment-related disputes be resolved through arbitration.
The trial court denied the motion to compel arbitration without providing a clear explanation for its ruling. This led the defendants to file an interlocutory appeal, seeking to overturn the lower court's decision.
The Ruling
The Texas Court of Appeals ruled in favor of the defendants, reversing the trial court's decision and ordering that the case be sent to arbitration. The court found that the defendants had successfully demonstrated the existence of a valid arbitration agreement and that Burns's claims were indeed covered by the agreement.
The court stated, "The record establishes that Appellants showed (1) the existence of a valid arbitration agreement and (2) that Burns’s claims fall within the agreement’s scope."
Justice Jennifer Caughey, along with Justices Guerra and Gunn, comprised the panel that made this ruling. The court emphasized that under Texas law, arbitration is favored, and parties must adhere to the agreements they have signed unless there is a valid reason to invalidate them.
Impact
This ruling has significant implications for employment disputes in Texas. It reinforces the enforceability of arbitration agreements in employment contracts, making it clear that employees may be required to resolve disputes through arbitration rather than in court. This decision could influence how employers draft their employment agreements and how employees understand their rights.
The court's ruling also clarifies the burden of proof regarding arbitration agreements. It establishes that once a valid agreement is shown, the burden shifts to the party opposing arbitration to prove a valid defense against it. This could discourage employees from pursuing claims in court if they have signed arbitration agreements.
What's Next
The case has been remanded back to the trial court, which is instructed to compel arbitration of Burns's claims and stay the trial proceedings until arbitration is completed. It is currently unclear if Burns will seek further appeal regarding this decision.