Bravo v. Dallas ISD

── Bravo v. Dallas ISD ── Court: Court of Appeals for the Fifth Circuit Date: June 01, 2026 Category: Civil Rights Case: 25-10982 Document: 70-1 Page: 1 Date Filed: 06/01/2026 United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit No. 25-10982 FILED June 1, 2026 ____________ Lyle W. Cayce Joe Martin Bravo, Clerk Plaintiff—Appellant, versus Dallas Independent School District; Tarrant Appraisal District, Defendants—Appellees. ______________________________ Appeal from the United States District Court for the Northern District of Texas USDC No. 3:23-CV-1596 ______________________________ Before Wiener, Haynes, and Graves, Circuit Judges. James E. Graves, Jr., Circuit Judge: The Dallas Independent School District fired Joe Bravo after six students complained that he made racially insensitive remarks in the classroom. He sued, alleging that the District discriminated against him based on his Mexican-American ancestry, violating Title VII of the Civil Rights Act. The district court granted the District summary judgment, reasoning that Bravo failed to produce sufficient evidence to establish a prima facie case of discrimination under McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). We AFFIRM. Case: 25-10982 Document: 70-1 Page: 2 Date Filed: 06/01/2026 No. 25-10982 I. Title VII prohibits employment discrimination on the basis of race, ethnicity, or national origin. 42 U.S.C. § 2000e-2(a). “[D]irect evidence of discriminatory intent is rare.” Saketkoo v. Adm’rs of Tulane Educ. Fund, 31 F.4th 990, 997 (5th Cir. 2022). So an employee usually “proves [their] claim [through] circumstantial evidence.” Id. If they use circumstantial evidence, they must satisfy the McDonell Douglas burden-shifting framework to survive summary judgment. Id. Under this framework, an employee must first establish a prime facie case. Id. This means they must offer sufficient evidence that they (1) are a member of a protected class, (2) were qualified for their position, (3) suffered an adverse employment action, and (4) were treated less favorably than “other similarly situated employees who were not members of the protected class, under nearly identical circumstances.” Lee v. Kan. City S. Ry. Co., 574 F.3d 253, 259 (5th Cir. 2009) (citation modified). The district court granted summary judgment at the fourth prong, because Bravo “fail[ed] to offer any evidence of a similarly situated comparator.” Bravo v. Dall. Indep. Sch. Dist., No. 3:23-CV-01596, 2025 WL 2163272, at *8 (N.D. Tex. July 30, 2025).1 He appeals. II. Bravo concedes that our precedent required him to show a similarly situated comparator. But he argues that a recent Supreme Court decision, Ames v. Ohio Department of Youth Services, overruled our previous cases that required him to do so. 605 U.S. 303 (2025). We disagree. _____________________ 1 “We review a district court’s grant of summary judgment de novo.” Barrett v. Atl. Richfield Co., 95 F.3d 375, 382 (5th Cir. 1996). 2 Case: 25-10982 Document: 70-1 Page: 3 Date Filed: 06/01/2026 No. 25-10982