Here, the Church did not present evidence of any statements to the Seminary relating to Shannon’s violation of any policy of the Church or failure to perform her job as required by the Church. The Church did not establish that Steane’s statement expressing doubts about Shannon’s ability to solicit donations for the Seminary was related to the manner in which she performed her job at the Church. At most, one might infer that Shannon left the Church on unfavorable terms, but these statements provide no analysis of her attendance, attitudes, effort, knowledge, behavior, or skills as Elementary Ministries Director. Accordingly, the Church has not conclusively established its entitlement to summary judgment on the affirmative defense of immunity under chapter 103.

Shannon v. Memorial Drive Presbyterian Church, U.S., — S.W.3d —, No. 14-14-00359-CV 2015 WL 4463919 at *8 (Tex. App.—Houston [14th Dist.] July 21, 2015).