Thrive Academy is a Texas private school for students with special needs. Jennifer Mitchell began working as the Director of Curriculum Development and a Lead Teacher at Thrive Academy in August 2020. Her employment contract stated it would run for “twelve months beginning August 1, 2020, unless terminated earlier,” and permitted termination “at any time, with or without cause.” The contract included a provision that if terminated early, her salary would be prorated “based on the fraction of the total employment term” worked.
Mitchell notified Thrive in January 2021 that she would not be returning for the next academic year and asked to begin transitioning her duties at the conclusion of the academic year. On May 21, 2021, Thrive terminated her employment effective May 28, the last day of the academic school year. Mitchell was not paid for June or July. She filed a wage claim with the Texas Workforce Commission (TWC) under the Texas Payday Act, asserting she was entitled to salary payments through July.
TWC denied the claim, finding that Mitchell’s final salary had been correctly prorated through her last day of work, and that although employees were paid over 12 months, her performance obligations had ended so was not entitled to unpaid wages. Mitchell appealed, and the trial court reversed the agency’s ruling, awarding her $10,300 in damages. Thrive and TWC then appealed to the Texas Court of Appeals.
In Texas, trial courts conduct review of TWC wage claim rulings under the substantial evidence standard. Courts are not permitted to substitute their judgment for the agency’s, and may only reverse if the decision lacks any reasonable basis or was arbitrary and capricious.
The appellate court focused first on the meaning of the phrase “total employment term” in Mitchell’s contract. Both sides presented reasonable interpretations: Mitchell argued the term referred to the academic year (August through May), while Thrive and TWC interpreted it to mean twelve calendar months. Because the contract was susceptible to more than one reasonable meaning, the Court deemed it ambiguous and allowed for the use of extrinsic evidence.
TWC’s findings of fact, based on the administrative record and evidence presented, supported its interpretation. The Commission found that Mitchell’s duties were not limited to the academic year and that her prior years of employment included summer responsibilities such as curriculum planning, summer camp development, student admissions, and preparing handbooks. Thrive’s president testified that Mitchell had regularly worked during the summer months, even if not physically on campus. TWC credited this testimony and determined that Mitchell’s work historically spanned a full 12-month cycle.
Although Mitchell disputed the nature of her summer work, arguing it was voluntary and not contractually required, the Court emphasized that fact disputes are for the agency to resolve, and the presence of conflicting testimony did not justify reversing the decision.
The Texas Court of Appeals reversed the trial court’s judgment and rendered judgment in favor of Thrive Academy and TWC. It held that substantial evidence supported TWC’s conclusion that Mitchell was not owed additional wages under the contract.
Thrive Acad. v. Mitchell (Tex. App. Oct. 9, 2025) 2025 Tex. App. LEXIS 7798.
Note: This case illustrates how courts will scrutinize ambiguous employment contracts, especially when a contract includes a fixed school-year term alongside broad at-will termination rights, as well as expectations for employees to work during the summer. Schools should ensure that contract terms are aligned and clearly defined.