Practice Area · Healthcare Retaliation

Front-line staff see what others miss. Texas law protects them when they report it.

Certified nursing assistants, certified medical assistants, and other front-line healthcare staff are mandatory reporters under Texas law — required to report abuse, neglect, and patient-safety violations they observe. When facilities respond by retaliating, the legal protections are real, the burden-shifting frameworks favor the reporter, and the damages can be substantial. In a recent §260A.014 arbitration, the firm obtained a Final Award of $375,681 on behalf of a Lead Certified Nursing Assistant and a housekeeping supervisor who reported resident abuse to state surveyors.

The Legal Framework

Six laws protect CNAs, CMAs, and front-line healthcare staff

Texas’s healthcare retaliation framework is built around a recognition that the people closest to patient care — and therefore most likely to observe abuse, neglect, or safety violations — are often the people with the least power inside the facility hierarchy. The statutes that protect them are deliberately structured to address that power imbalance: each carries a 60-day rebuttable presumption that shifts the burden to the facility, each prohibits not just outright termination but the full range of subtler adverse actions, and most extend to non-employees and agency workers as well as direct hires.

1. Texas Health & Safety Code §260A.014 — Long-term care retaliation

Section 260A.014 is the primary statute protecting CNAs, CMAs, nursing assistants, housekeeping staff, dietary staff, and other front-line workers at long-term care facilities — nursing homes, assisted living, intermediate care facilities for individuals with intellectual disabilities, memory care units, residential treatment centers, and similar settings. The statute protects two distinct kinds of protected activity:

First, internal or external reports of a violation of law, abuse, neglect, or exploitation of a resident.

Second, cooperation with a Texas Health & Human Services investigation, an HHS survey, or any other governmental investigation or proceeding relating to care, services, or conditions at the facility.

The cooperation prong matters because long-term care facilities are subject to regular state surveys. When a survey is triggered by an internal complaint or an external report, the staff members who cooperate with the surveyors — including by providing written or oral statements identifying the conduct at issue — are protected. In a recent AAA arbitration matter, the firm represented two long-term care employees — a housekeeping supervisor and a Lead Certified Nursing Assistant who had risen through the ranks to Staffing Coordinator — who reported to HHS surveyors what they had seen and learned about the alleged mistreatment of a memory-care resident with dementia. Within weeks of those reports, one was fired outright and the other was stripped of her permanent role. The arbitrator found for both claimants, applying the but-for causation standard articulated by the Texas Supreme Court in Apache Corp. v. Davis, and entered a Final Award of $375,681.

The 60-day rebuttable presumption under §260A.014(f) is the procedural lever that makes these claims work. A protected report followed within 60 days by suspension, termination, position change, or other adverse action shifts the burden to the facility — which must come forward with evidence of a non-retaliatory reason before the analysis moves to but-for causation under Apache Corp. v. Davis.

See /texas-260a-long-term-care-retaliation/ for the full statutory framework.

2. Texas Health & Safety Code §260A.002(a) — The CNA’s mandatory reporting duty

Section 260A.002(a) is the statute that creates the most distinctive feature of CNA retaliation cases. It makes reporting mandatory for any employee of a long-term care facility who has cause to believe a resident has been subjected to abuse. The verb is “shall.” The obligation is not optional, and a CNA who fails to report may herself face investigation, discipline, and Nurse Aide Registry consequences.

The mandatory-reporting framework changes the litigation posture of every §260A.014 retaliation case. When the facility’s pretextual rationale for termination is “performance” or “restructuring,” the CNA can credibly respond that she was doing what the statute required. The facility’s witnesses often concede the same point under oath: a CNA who observes abuse or neglect has an obligation to report it. That concession effectively forecloses any argument that the report itself was inappropriate, and shifts the litigation to the much harder ground of explaining why the report was followed so closely by the adverse action.

The Mandatory Reporting Duty
Texas Health & Safety Code §260A.002(a)

“A person, including an owner or employee of a facility, shall report the abuse, neglect, or exploitation of a resident if the person has cause to believe that a resident has been subjected to abuse, neglect, or exploitation.” The obligation is unconditional. A supervisor’s instruction to remain silent does not override the duty. A facility policy that requires going up the internal chain before any external report does not override the duty. And a facility’s claim that the matter was “handled internally” does not override the duty.

3. Texas Health & Safety Code §161.134 — Hospital and treatment-facility retaliation

For CNAs and CMAs working in hospital settings — acute care, hospital-based skilled nursing units, inpatient psychiatric facilities, residential treatment centers, and outpatient hospital-affiliated programs — §161.134 provides parallel retaliation protection. The statute prohibits hospitals, mental health facilities, and treatment facilities from suspending, terminating, disciplining, or otherwise retaliating against an employee who reports a violation of law in good faith.

The Texas Supreme Court in El Paso Healthcare System v. Murphy, 518 S.W.3d 412 (Tex. 2017), articulated the good-faith standard: the report is protected if “a reasonable person would conclude” the conduct reported constitutes a violation of law. A CNA’s professional training and patient-care experience inform what counts as “reasonable” — the standard is not measured against a layperson’s expectations.

Section 161.134’s reach is broad. Reports of medication errors, infection-control failures, unsafe staffing ratios, controlled-substance diversion, falsification of patient records, billing fraud, and similar patient-safety concerns are all within its scope. The companion provision, §161.135, extends protection to non-employees — including agency CNAs, contract CMAs, and per diem staff whose working relationship is with a staffing agency rather than directly with the facility.

See /texas-health-safety-code-161-134/ and /texas-health-safety-code-161-135/.

4. Texas Family Code §§261.101 and 261.110 — Child abuse reporting

CNAs and CMAs working with children — in pediatric units, adolescent residential treatment facilities, school-based health programs, federally funded residential children’s facilities, or any setting involving minors — are subject to Texas Family Code §261.101‘s mandatory child abuse reporting obligation. The duty applies to “any person” with cause to believe a child has been adversely affected by abuse or neglect. Section 261.110 then prohibits employers from retaliating against the reporter for fulfilling that obligation.

The firm has represented an employee at a federally funded residential children’s facility — a setting that participates in the federal Office of Refugee Resettlement Unaccompanied Children Program and accepts the whistleblower-policy obligations that come with that funding. The employee reported a coworker’s policy violation involving a former resident, and the facility terminated her within hours of receiving her written report. The §261.110 framework, alongside the federal whistleblower-protection statute that applies to federal contractors and grantees, governs that fact pattern.

The 60-day rebuttable presumption applies to §261.110 claims, parallel to §260A.014 and §161.134.

See /texas-family-code-261-110-child-abuse-reporting/.

5. Texas Human Resources Code §36.115 — TMFPA retaliation for reporting Medicaid fraud

The Texas Medicaid Fraud Prevention Act protects CNAs and CMAs who report Medicaid billing fraud, kickback arrangements, or other Medicaid-related violations. The statute applies broadly — any setting where Medicaid billing is involved is within its reach. For CNAs in long-term care this means almost every facility (Medicaid is the primary payer in most Texas nursing homes); for CMAs in physician offices it reaches any practice that bills Medicaid; for hospital-based CNAs and CMAs it reaches Medicaid billing across the entire institution.

Section 36.115’s damages structure differs from the other retaliation statutes. The statutory remedy includes “not less than two times the amount of back pay, [and] interest on the back pay” — a doubled-back-pay provision distinct from the lost-wages frameworks under §161.134 and §260A.014.

See /texas-medicaid-fraud-prevention-act/.

6. Sabine Pilot — Refusing to commit a crime

The Texas Supreme Court’s Sabine Pilot doctrine — Sabine Pilot Serv., Inc. v. Hauck, 687 S.W.2d 733 (Tex. 1985) — provides a common-law cause of action for at-will employees who are terminated for refusing to perform an illegal act that carries criminal penalties.

For CNAs and CMAs, Sabine Pilot most often reaches refusals to falsify medication administration records, refusals to chart care that was not delivered, refusals to administer medications outside the scope of CNA or CMA practice, refusals to participate in resident abuse, and refusals to participate in Medicaid billing for services not rendered. Medicaid fraud is a criminal offense under Texas Penal Code §35A.02, ranging from a Class C misdemeanor to a first-degree felony depending on the amount, so a CNA’s refusal to chart fraudulent care can support a Sabine Pilot claim independently of the §36.115 retaliation framework.

Sabine Pilot is a common-law remedy, so the statutory rebuttable presumptions do not apply. Causation must be proven through the standard circumstantial-evidence framework, but the doctrine reaches conduct that the statutory framework may not.

See /sabine-pilot/.

The Reporting Catch-22

CNAs are required to report — and then face retaliation for doing it

Texas law does not just permit CNAs to report abuse, neglect, and patient-safety concerns. In most contexts it requires them to. The combination of mandatory-reporting duties and the retaliation that often follows creates a legal Catch-22 that is more acute for CNAs than for almost any other category of worker.

§260A.002(a) requires LTC employees to report resident abuse. The duty is mandatory and unconditional.

§261.101 requires any person, including CNAs and CMAs, to report suspected child abuse or neglect. The duty applies to anyone with cause to believe abuse has occurred — the threshold is lower than certainty.

Nurse Aide Registry standards include conduct expectations that overlap with the mandatory-reporting framework. A CNA who fails to report observed abuse may herself face Registry investigation.

The result is a legal posture in which the CNA who reports is fulfilling a statutory duty — and the CNA who does not may face her own consequences. Texas’s retaliation statutes exist to close the gap between those two pressures. They protect the CNA’s ability to fulfill her mandatory reporting duties without losing her job. But in practice, the gap closes only after litigation, and the CNA must absorb the financial and professional disruption in the meantime.

The CNA who fails to report mandatory-reporting conduct faces Registry discipline. The CNA who reports faces facility retaliation. Texas’s retaliation statutes exist to close that gap — but only after the CNA has already paid the price.
The Reporting Catch-22 for CNAs

This matters for litigation positioning. When the facility’s pretextual rationale is “performance issues” or “restructuring,” the CNA can credibly respond that she was doing what the statute required. Facility witnesses commonly concede the same point under oath. Such concessions effectively foreclose any argument that the report itself was inappropriate, and shift the litigation to the much harder ground of explaining why the report was followed so closely by the adverse action.

Protected Activity

What counts as a protected report

Texas law does not require the CNA to be right about the underlying violation to be protected. What is required is a good-faith, objectively reasonable belief that the reported conduct constituted abuse, neglect, exploitation, or another violation of law. The CNA’s training and direct observation of patient care inform what counts as “reasonable” — a CNA’s reasonable belief is not measured against a layperson’s standard.

The protection covers reports made through several different channels:

  • Internal reports to the charge nurse, DON, administrator, or compliance department. A report up the internal chain — to the charge nurse, the unit director, the director of nursing, the administrator, or a compliance officer — is protected. So is a report made through the facility’s own internal incident-reporting system, and a report filed under a facility hotline or safety policy.
  • External reports to HHSC or other state regulators. Reports to the Texas Health and Human Services Commission (the long-term care surveying agency), the Texas Department of State Health Services, the Texas Department of Family and Protective Services, the Texas Medical Board (when physician conduct is at issue), or the Texas Board of Nursing (when nurse conduct is at issue) are all protected. So are reports to law enforcement.
  • External reports to federal agencies. Reports to the federal Office of Inspector General, the Centers for Medicare & Medicaid Services, the Drug Enforcement Administration, or other federal agencies are protected — though the protecting statute may be federal (the False Claims Act, the NDAA whistleblower-protection statute for federal contractors and grantees, the EMTALA whistleblower provision) rather than Texas state law.
  • Cooperation with a state survey already underway. When an HHSC surveyor arrives to investigate a complaint, the CNA who provides truthful information to that surveyor is protected. This protection holds even when the cooperation is solicited by the surveyor rather than initiated by the CNA — including written statements provided to surveyors in the course of a survey investigation.

What distinguishes a protected report from mere speculation is personal observation or direct knowledge. Texas courts have distinguished cases where the reporter speculated about events she did not witness from cases where the reporter personally observed the violation. When a CNA personally witnesses a coworker striking a resident, a colleague administering the wrong medication, a supervisor instructing staff to delay turning bedridden residents, or a charge nurse falsifying documentation, that is direct knowledge — not speculation — and the good-faith requirement is easily satisfied.

Patterns of Retaliation

What retaliation looks like in CNA and CMA cases

Facilities rarely admit to retaliating against a CNA for reporting abuse, neglect, or patient-safety concerns. The retaliation is almost always framed as a “performance issue,” a “restructuring,” a “scheduling decision,” a “policy violation,” or a “concerning incident.” Texas law accommodates this reality by allowing CNAs to prove retaliation through circumstantial evidence, and Texas courts have catalogued the patterns that point to retaliatory motive.

The leading framework is the five-factor test from Continental Coffee Products Co. v. Cazarez, 937 S.W.2d 444 (Tex. 1996), which Texas courts apply across retaliation statutes: knowledge of the protected activity by decision-makers; negative attitude toward the protected activity; failure to follow established facility policies; discriminatory treatment compared to similarly situated employees; and evidence that the stated reason was false. Temporal proximity is also commonly considered.

In Ball v. Alleyton Resource Co., No. 14-19-00816-CV (Tex. App.—Houston [14th Dist.] June 3, 2021), the Fourteenth Court of Appeals affirmed a $1.7 million jury verdict in a workers’ compensation retaliation case where the proof was almost entirely circumstantial. The Texas Supreme Court denied review. The proof framework transfers directly to CNA retaliation cases — facility witnesses contradicting each other, the absence of contemporaneous documentation, the facility’s own policies used as cross-examination, temporal proximity between the report and the adverse action.

In Practice

The most powerful evidence in a CNA retaliation case is often evidence the facility did not expect to be produced — internal incident reports, HHSC surveyor notes obtained through state-agency records requests, contemporaneous text messages between supervisors, scheduling records showing the gradual phase-out of the reporter, and the personnel files of the employees accused of the underlying conduct. The first task in any CNA retaliation case is to identify what documents exist, where they live, and how to compel their production before they are destroyed under routine retention policies.

Termination shortly after the report

When the adverse employment action occurs within the statutory 60-day presumption window — or even outside that window when other evidence points to retaliation — temporal proximity is a powerful indicator. Texas courts have found termination approximately one month after a protected activity to be sufficient evidence of causation.

Position change, demotion, or PRN reclassification

When the facility cannot terminate the CNA outright without raising obvious retaliation questions, a position change may be used instead. The CNA is moved from a daily schedule to PRN (as-needed) status and then never scheduled, stripped of supervisory or charge responsibilities, transferred to a less desirable unit, or shifted to a schedule designed to make continued employment impractical. Texas law recognizes that a transfer to an “objectively worse” position is itself an adverse employment action. In the §260A.014 arbitration matter described above, one of the two claimants was stripped of her permanent role rather than terminated outright — and the arbitrator treated that demotion as an adverse action within the statute.

Differential treatment of the reporter versus the accused

When the CNA who reported is disciplined while the coworkers who engaged in the underlying conduct are not — or are returned to work after only brief discipline — the disparate treatment is direct circumstantial evidence of retaliation. In the §260A.014 arbitration matter, the employees accused of the underlying conduct were briefly disciplined and returned to work; the housekeeping supervisor who reported them was suspended and terminated.

The absence of a paper trail before the report

In Ball v. Alleyton, the firm proved retaliation in part by demonstrating that for ten months preceding the termination, the company had issued the plaintiff zero write-ups, incident reports, or disciplinary actions — even though company policy required contemporaneous documentation of performance issues. The same dynamic shows up in CNA retaliation cases. When the facility claims a pattern of performance problems but cannot produce a single contemporaneous write-up, performance improvement plan, verbal warning, or in-service requirement, the absence of documentation is itself evidence that the alleged performance problems were not the real reason for the adverse action.

“Restructuring,” “reorganization,” or “right-sizing” pretext

Facilities sometimes claim that the role was eliminated, restructured, or “right-sized” — that the CNA’s departure had nothing to do with her conduct. When the replacement hired into the “restructured” position actually performs the same work (sometimes at the same hours or schedule), the restructuring claim collapses. When the facility hires a new CNA shortly after the reporter’s termination, the claim collapses faster.

Hostility toward the protected activity itself

When supervisors confront the reporter to ask why she spoke to a state surveyor, what she told them, why she involved external agencies, or why she “didn’t keep it in-house,” the hostility toward the protected activity is itself probative evidence. So is any instruction to lie to a surveyor, downplay the conduct reported, or recharacterize the report after the fact.

Retaliatory referral to the Nurse Aide Registry

A particularly damaging retaliation pattern: the facility responds to the CNA’s protected report by filing its own complaint to the Nurse Aide Registry, alleging that the CNA’s conduct — not the conduct she reported — was the real problem. The facility’s filing triggers a Registry investigation that the CNA must defend at the same time she is dealing with the loss of her job. The pattern is recognized by Texas law and the same evidence that proves the underlying retaliation supports a challenge to the Registry filing.

The facility’s own handbook and policies, used as cross-examination

Ball v. Alleyton illustrates a particularly effective approach: the company’s safety administrator was forced to confirm, on the stand, that the rules required communication, progressive discipline, fair application, and documentation — and was then walked through each requirement the company had violated. The same approach works in CNA retaliation cases. Facility employee handbooks, abuse-reporting policies, progressive-discipline protocols, and orientation materials are routine sources of impeachment against the facility’s after-the-fact justifications.

Procedural Advantage

The 60-day rebuttable presumption

Texas’s healthcare retaliation statutes share a parallel structural feature: each contains a rebuttable presumption that the facility’s adverse action was retaliatory if it occurred within 60 days of a good-faith protected report.

  • §260A.014(f) — long-term care facilities
  • §161.134(f) — hospitals and treatment facilities
  • §261.110 — child abuse reporting
  • §36.115 — TMFPA

The structural significance is that the burden of production shifts to the facility at the threshold stage. Texas courts begin with the assumption that termination, suspension, demotion, or position change within 60 days of a protected report was retaliatory. The facility must come forward with evidence of a non-retaliatory reason — and that reason must withstand the pretext analysis described above.

Once the facility offers any non-retaliatory explanation, the presumption is rebutted, and the CNA must prove but-for causation — the standard articulated by the Texas Supreme Court in Apache Corp. v. Davis. The 60-day presumption matters most at the early procedural stages of a case. By trial, the case will turn on the same evidentiary record the CNA would otherwise have to develop. The presumption is a procedural advantage, not a substitute for proof.

The 60-day window starts running from the date of the protected report. When the protected activity involves multiple reports — an internal report followed by an HHSC complaint, for example — the window can restart with each report.

Damages

What a CNA or CMA can recover

Texas law allows CNAs and CMAs who prevail in retaliation cases to recover several distinct categories of damages.

Lost wages, past and future. Back pay from the date of termination through trial, plus a lost-future-earning-capacity calculation through the worker’s work-life expectancy. Lost-wages calculations are typically supported by an economic expert. For CNAs and CMAs, the future-earnings analysis often includes the impact of the termination on advancement opportunities — the difference between the CNA’s trajectory toward LVN or RN training and the slower trajectory that follows a Registry inquiry or a facility termination on record.

Mental anguish. The Texas Supreme Court’s decision in Gregory v. Chohan, 670 S.W.3d 546 (Tex. 2023), established the rational-basis framework for non-economic damages in Texas. Rational-basis methodologies — such as calculations tied to the smallest unit of money applied over the smallest unit of time across the worker’s life expectancy — produce substantial mental anguish recoveries while satisfying the Chohan standard.

Punitive damages. Texas allows punitive damages under Ancira Enterprises, Inc. v. Fischer, 178 S.W.3d 82 (Tex. App.—Austin 2005, no pet.), when the facility was “aware that it is or may be violating the law.” Corporate witnesses in CNA retaliation cases routinely concede in deposition that they had specific training on the anti-retaliation statutes and on §260A.002(a)’s mandatory reporting framework — testimony that satisfies the Ancira awareness requirement. In Ball v. Alleyton, the jury awarded $750,000 in exemplary damages on a gross negligence finding, affirmed by the Fourteenth Court of Appeals.

Doubled back pay under §36.115. When TMFPA is the protecting statute, the CNA or CMA is entitled to “not less than two times the amount of back pay, [and] interest on the back pay” by statute.

Attorney’s fees and litigation costs. Texas’s healthcare retaliation statutes contain fee-shifting provisions for the prevailing plaintiff. In §260A.014 arbitration matters, the fee award typically represents a substantial component of the total recovery — reflecting the procedural complexity of the work and the importance the legislature placed on enforcement.

The firm’s representative results in retaliation matters provide the damages benchmark. In the §260A.014 arbitration matter described above, the arbitrator entered a Final Award of $375,681 — including $11,304 in past wage loss and $54,894 in future wage loss for Claimant A, plus $5,000 in past wage loss for Claimant B; past mental anguish of $15,000 for Claimant A and $75,000 for Claimant B; prejudgment interest; and $190,323 in attorney’s fees, $3,558 in paralegal fees, and $6,508 in recoverable costs and expenses. In Ball v. Alleyton Resource Co., a Fort Bend County jury awarded $1,706,187 across all damage categories, unanimously affirmed by the Fourteenth Court of Appeals. In Newberne v. North Carolina Department of Public Safety, a Wake County jury awarded $1.1 million on a willful violation finding; the final judgment, including prejudgment interest and statutory attorney’s fees, totaled approximately $1.97 million.

Why It Matters

Why CNAs and CMAs face a distinct risk

Several features of CNA and CMA practice combine to make retaliation cases particularly serious for front-line healthcare workers — both at the time of the retaliation and in the years that follow.

Nurse Aide Registry consequences. The Texas Health and Human Services Commission maintains the Nurse Aide Registry. An adverse finding — abuse, neglect, theft, or “mistreatment” — can result in the CNA being permanently barred from working as a CNA at any licensed long-term care facility in Texas. This is the equivalent for CNAs of the Board of Nursing for RNs or the National Practitioner Data Bank for physicians. Facilities sometimes weaponize the Registry by filing their own complaints against a CNA whose report they want to discredit. The firm can address Registry proceedings alongside the underlying retaliation matter.

The mandatory-reporting Catch-22. The CNA who fails to report mandatory-reporting conduct faces Registry discipline. The CNA who reports faces facility retaliation. Texas’s retaliation statutes exist to close this gap, but in practice the gap closes only after litigation — and the CNA must absorb the disruption in the meantime.

Hierarchical vulnerability. CNAs and CMAs are usually low in the staff hierarchy. They are easier to retaliate against than licensed nurses, easier to schedule out than department managers, and easier to characterize as having “performance issues” than salaried administrative staff. The same hierarchical position that makes them effective patient advocates makes them attractive targets for retaliation.

The silencing effect on front-line patient safety. CNAs are typically the front-line staff with the most direct, sustained contact with residents and patients. They are the ones turning patients, bathing residents, transferring people between beds and chairs, feeding meals, and observing what happens around the clock. When experienced CNAs are terminated for reporting safety concerns, the message to remaining staff is unmistakable: do not report. The harm extends beyond the individual CNA to every patient who depends on the facility going forward. This systemic harm is part of why Texas’s retaliation statutes carry punitive-damages potential and why the 60-day rebuttable presumption shifts the burden to the facility.

Wage-loss as a higher proportion of overall economic security. CNAs and CMAs typically earn lower hourly wages than licensed staff. Even a relatively short period of unemployment can produce serious financial harm — missed rent, lost health insurance, depleted savings, the need to take whatever replacement work is available regardless of how it affects long-term advancement. The lost-future-earning-capacity component of damages reflects this reality.

In Practice

A CNA retaliation matter can require parallel proceedings in three forums simultaneously — the underlying employment matter, the state surveyor process at HHSC if a survey was triggered by the report, and the Nurse Aide Registry inquiry if the facility filed a Registry complaint as part of its retaliation. Each has different rules of evidence, different discovery scope, and different timing. The firm’s intake process is designed to identify all three forums at the outset rather than discover them mid-litigation.

Staffing agency complexity. Many CNAs work through staffing agencies that place them at facilities on a contract or per diem basis. Multi-entity employment structures raise questions about which entity is the proper defendant — the staffing agency, the facility, or both. Texas Health & Safety Code §161.135’s non-employee protection and the joint enterprise doctrine provide pathways for holding both entities accountable. Sorting out the correct defendant structure is part of the firm’s initial intake analysis.

Career disruption beyond the immediate facility. A retaliation termination — particularly one accompanied by a Registry filing or by negative references — can foreclose CNA opportunities at competing facilities for months or years. The lost earning-capacity component of damages reflects this reality.

The Firm

How the firm handles CNA and CMA retaliation matters

Doyle Dennis Avery LLP represents CNAs, CMAs, and front-line healthcare workers in retaliation matters where the conduct was egregious and the documentation supports a strong evidentiary record. The firm’s practice is selective by design: front-line healthcare retaliation cases require substantial investment in discovery, expert work, parallel-forum management (Registry, HHSC surveys, the underlying employment matter), and the kind of multi-statute claim development described above. The firm pursues a small number of these matters at any one time to ensure that each receives the depth of preparation the underlying conduct deserves.

Two of the firm’s named partners are board certified by the Texas Board of Legal Specialization. Jeffrey Avery is board certified in Labor and Employment Law. Michael Patrick Doyle is board certified in Personal Injury Trial Law.

The firm typically opens CNA and CMA retaliation engagements with a confidential initial consultation, followed by a documentation review and a written intake analysis identifying the relevant statutes, the relevant forums, and the procedural posture. Where the matter meets the firm’s criteria, representation proceeds on a contingency basis.

Recognition & Representative Authority
Verifiable record in retaliation and healthcare litigation
§260A.014 AAA Arbitration — Final Award of $375,681 (2026)
American Arbitration Association · Three-day evidentiary hearing · Final Award entered April 2026 · Applying Apache Corp. v. Davis but-for causation

Long-term care retaliation matter on behalf of a housekeeping supervisor and a Lead Certified Nursing Assistant who had risen to Staffing Coordinator. Both reported alleged mistreatment of a memory-care resident with dementia to HHS surveyors; within weeks, one was fired and the other stripped of her permanent role. The arbitrator found for both claimants and entered a Final Award including past and future wage loss, past mental anguish, prejudgment interest, attorney’s fees, paralegal fees, and recoverable costs and expenses.

Alleyton Resource Co. v. Ball, No. 14-19-00816-CV (Tex. App.—Houston [14th Dist.] June 3, 2021)
Fourteenth Court of Appeals · $1,706,187 verdict unanimously affirmed · Texas Supreme Court denied petition for review

Workers’ compensation retaliation matter. Trial team: Doyle, Dennis, and Avery. Verdict included $750,000 in exemplary damages on a gross negligence finding. The case is final, and the proof framework — circumstantial-evidence retaliation proof through documentary contradiction, witness inconsistency, and policy-based cross-examination — transfers directly to CNA retaliation matters where the facility relies on facially neutral performance or restructuring rationales.

Salas v. Fluor Daniel Services Corp., 616 S.W.3d 137 (Tex. App.—Houston [14th Dist.] 2020, pet. denied)
Fourteenth Court of Appeals · No-evidence summary judgment reversed · Published authority on §451.001 circumstantial proof

Retaliation case where the trial court had granted summary judgment on the employer’s facially neutral rationale. The Court of Appeals reversed, confirming that close temporal proximity combined with the surrounding evidentiary record defeats summary judgment. The published opinion remains citable Texas authority.

Newberne v. North Carolina Department of Public Safety, Wake County Superior Court, No. 02-CVS-4500
Wake County Superior Court · Verdict Sept. 28, 2016 · Final Judgment Feb. 16, 2017 · ~$1.97 million

Whistleblower retaliation matter following a unanimous 2005 N.C. Supreme Court ruling clarifying the Whistleblower Act. A unanimous Wake County jury returned $1.1 million on a willful violation finding; final judgment, including prejudgment interest, costs, and statutory attorney’s fees awarded by the court, totaled approximately $1.97 million.

CLE Presentations on Retaliation Litigation
Dallas Bar Association · Labor & Employment Section (Sept. 2021) · NELA Houston (Feb. 2021)

“The Anatomy of a Worker’s Compensation Retaliation Trial” and “Report from the Battlefield: Observations and Review from Ball v. Alleyton Resources Co.” — invited presentations by trial counsel after the verdict and appellate affirmance, addressing circumstantial-evidence retaliation proof transferable across statutory frameworks.

Frequently Asked

What CNAs and CMAs ask about retaliation

Can my long-term care facility fire me for reporting resident abuse?
No. Texas Health & Safety Code §260A.014 prohibits long-term care facilities from retaliating against employees who report abuse, neglect, or exploitation of a resident, or who cooperate with state surveyor investigations. If the facility terminates you, demotes you, restructures your role, or takes other adverse action within 60 days of your report, Texas law begins with the presumption that the action was retaliatory. The facility must then come forward with a non-retaliatory reason — and that reason must withstand scrutiny under the but-for causation standard articulated by the Texas Supreme Court in Apache Corp. v. Davis.
Am I required to report what I saw, even if my supervisor told me not to?
Yes. Texas Health & Safety Code §260A.002(a) requires any employee of a long-term care facility who has cause to believe a resident has been subjected to abuse to report the abuse. The verb the statute uses is “shall” — the obligation is mandatory. A supervisor’s instruction to remain silent does not override the statutory duty, and it may itself become evidence in any retaliation case that follows. Similar mandatory reporting obligations apply under Texas Family Code §261.101 when the suspected abuse involves a child.
What happens to my place on the Nurse Aide Registry if I report and then get fired?
Facilities sometimes respond to a CNA’s protected report by filing their own complaint to the Nurse Aide Registry — alleging that the CNA’s conduct, not the conduct she reported, was the real problem. This is a recognized retaliation tactic, and the firm can address the Registry inquiry alongside the underlying retaliation matter. Texas law allows the same evidence that proves the underlying retaliation to support a challenge to the Registry filing.
I work through a staffing agency, not as a direct facility employee. Am I protected?
Yes. Texas Health & Safety Code §161.135 extends parallel protection to non-employees whose work depends on facility access or assignment. Agency CNAs, contract CNAs, and per diem staff are within the statute’s reach. The joint enterprise doctrine and the §161.135 non-employee framework provide pathways for holding both the staffing agency and the facility accountable where the working relationships span them. Sorting out the right defendant structure is part of the firm’s initial intake analysis.
What if I am a CMA in a physician office, not a CNA in long-term care?
Certified medical assistants in physician offices, ambulatory surgery centers, and outpatient clinics are protected by a different combination of statutes than CNAs in long-term care. The §260A.014 framework typically does not reach physician offices, but §161.134’s protection for reports to hospitals and treatment facilities can apply to ambulatory surgery centers and similar settings. The Sabine Pilot doctrine reaches CMAs in any setting who refuse to participate in illegal conduct — including Medicaid fraud, falsification of medical records, or controlled-substance violations. The Texas Medicaid Fraud Prevention Act under Texas Human Resources Code §36.115 reaches CMAs who report billing fraud in any Medicaid-participating setting. And federal statutes — the False Claims Act, the NDAA whistleblower-protection statute, OSHA-administered whistleblower laws — may apply depending on the underlying conduct.
How long do I have to bring a claim?
Limitations periods vary by statute. The Texas healthcare retaliation statutes generally allow at least two years; some run from the date of unequivocal written notice of termination rather than from an earlier verbal communication. Sabine Pilot claims and common-law claims have their own limitations frameworks. Time is of the essence in any retaliation matter, and any CNA or CMA who suspects she has a retaliation claim should consult with counsel as soon as possible.
What can I recover if I prevail?
Damages typically include past and future lost wages, mental anguish, and where the conduct warrants, exemplary damages. Attorney’s fees and litigation costs are recoverable under most of the Texas healthcare retaliation statutes. In a recent §260A.014 arbitration the firm handled, the arbitrator entered a Final Award of $375,681 to two long-term care employees — including past and future wage loss, past mental anguish, prejudgment interest, attorney’s fees, paralegal fees, and recoverable costs. The fee award typically represents a substantial component of the total recovery, reflecting the procedural complexity of the work.
The facility said I’m being demoted to PRN, not fired. Is that still retaliation?
Yes. Texas law recognizes that a transfer to an objectively worse position — being moved from a daily schedule to an as-needed (PRN) status and then never scheduled, stripped of supervisory or charge responsibilities, or transferred to a less desirable role — is itself an adverse employment action regardless of whether the facility also formally terminates the employee. In a §260A.014 arbitration matter the firm handled, one of the two claimants was stripped of her permanent role rather than terminated outright, and the arbitrator treated that demotion as an adverse action within the statute.
JA
Reviewed By
Jeffrey I. Avery · Partner, Doyle Dennis Avery LLP
Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization · Texas Bar No. 24085185 · Invited speaker on Ball v. Alleyton before NELA Houston (2021) and the Dallas Bar Association Labor & Employment Section (2021)
Common Questions

What people ask before reaching out.

How do I know if I have a case?+

We evaluate every case evaluation submission. The threshold question is whether the adverse action you experienced was motivated, in whole or in part, by protected activity — reporting misconduct, refusing to violate the law, asserting workers’ compensation rights, reporting harassment, or engaging in other legally protected conduct. The exact framework depends on the statute that applies, but the analytical question is the same. We will tell you what we see in your case and what makes it strong or difficult.

How is the firm paid?+

We work on a contingency-fee basis in qualifying retaliation and employment matters. There is no upfront cost to you. We are paid only if we recover for you, as a percentage of the recovery. If we do not recover for you, you do not owe us a fee. Litigation expenses are typically advanced by the firm and reimbursed from any recovery. The specific contingency rate and expense terms are disclosed in writing in the engagement agreement before representation begins.

Will my employer find out I contacted a lawyer?+

No. Communications during a case evaluation are confidential under the attorney-client privilege from the moment you contact us, regardless of whether we ultimately take your case. We do not contact your employer, send notices, or take any action without your authorization. Many of our matters proceed for months in a fully confidential posture before any external action is taken. The decision about when and how to surface a claim is made strategically, with your input, at the right moment.

What happens after I submit the case evaluation form?+

A senior attorney typically reviews submissions within one business day. If your matter fits the firm’s practice and presents a viable claim, we will contact you to discuss next steps. If your matter does not fit our practice, we will tell you that directly and, where possible, point you toward attorneys who handle the relevant area. We aim to give every submission a substantive response, not silence.

How quickly will I hear back?+

We aim to respond to every case evaluation submission within one business day. Time-sensitive matters — particularly those approaching statute of limitations deadlines — receive priority response. If you have an imminent deadline or have already received a right-to-sue letter or similar timing-critical document, please note that in your submission so we can prioritize accordingly.

See more questions on the full FAQ page or start your case evaluation.

Are You a CNA or CMA Facing Retaliation?

Reporting what you’re trained to see should not cost you your job.

If you were suspended, demoted, restructured, moved to PRN status, or terminated after reporting abuse, neglect, billing fraud, or another violation of law, you may have a claim under one or more Texas statutes. Consultations are confidential and free.

Speak with our team →

Past results do not guarantee a similar outcome in any future matter. Every case is different, and outcomes depend on the specific facts and applicable law.

This page is attorney advertising. The content is for informational purposes only and does not constitute legal advice. Reading this page does not create an attorney-client relationship.

Statutory citations are current as of the date of publication and may change. Limitations periods vary by statute and by the facts of the individual matter; any CNA, CMA, or other healthcare worker considering a retaliation claim should consult with counsel promptly.

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