Employment Discrimination Claims Fall Outside Business Court's 'Internal Affairs' Jurisdiction

In Brown v. Exxon Mobil, the Business Court remanded a Texas Labor Code Section 21.051 race discrimination claim, holding that employment termination disputes—even involving executive compensation and RSUs—do not constitute actions regarding an organization's "internal affairs" under Section 25A.004(b)(2) or arise from a "qualified transaction" under Section 25A.004(d)(1). Judge Sweeten's opinion establishes that the Business Court lacks subject matter jurisdiction over statutory employment discrimination claims despite their connection to corporate governance structures and equity-based compensation.