Date: 06-13-2025

Case Style:

Greta J. Hurt, et al. v. City of Tulsa, Oklahoma

Case Number: 22-CV-227

Judge: John D. Russell

Court: United States District Court for the Northern District of Oklahoma (Tulsa County)

Plaintiff's Attorney: Joel Whlgemuth, John Nicks, Linda Morrissey

Defendant's Attorney: City of Tulsa Legal Department

Description: Tulsa, Oklahoma civil rights lawyers are representing the Plaintiffs on 42 U.S.C. 2000e job discrimination theories.


COMPLAINT
Plaintiffs Greta J. Hurt and Julie D. Lynn, ("Hurt" and "Lynn") allege:
1. This action is brought on behalf of the Plaintiffs to enforce the provisions of Title VII
of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000 et seq. ("Title VII"). As set forth below,
the Plaintiffs allege that Defendant, the City of Tulsa, Oklahoma, Fire Department ("Defendant" or
"TFD"), has engaged in sex discrimination in violation of Title VII when it subjected firefighters Greta
Hurt ("Hurt") and Julie Lynn ("Lynn") to discrimination in the Fire Department promotion process
and to a hostile work environment based on their sex. The TFD subjected Lynn to retaliation because
she filed a complaint and further subjected Hurt to retaliation because of her complaints of sex
discrimination which ultimately resulted in her constructive discharge.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this action under 42 U.S.C. §§ 2000e-S(t)(3), 28
U.S.C. §§ 1331, 1343(a).
3. Hurt and Lynn timely filed a charge alleging sex discrimination and retaliation with
the Equal Employment Opportunity Commission ("EEOC"). Hurt's charge is denoted by the EEOC ··4-~
I ~✓'\
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as Charge No. 564202200747. Lynn's charge is denoted by the EEOC as Charge No. 564202200748.
4. On June 30, 2022 the EEOC issued and mailed a Notice of Right to Sue to Hurt and
Lynn, attached as exhibits hereto.
5. All conditions precedent to the initiation of this lawsuit have been fulfilled.
6. The employment practices alleged to be unlawful were committed within the
jurisdiction of the United States District Court for the Northern District of Oklahoma. Therefore,
venue is proper in this judicial district under 42 U.S.C. § 2000e-5(f) and 28 U.S.C. § 1391(b).
PARTIES
7. Plaintiffs are employeesof the City ofTulsa, as that term is defined in 42 U.S.C. § 2000e
and they are expressly authorized to bring this action by Sections 717(c) of Title VII, 42 U.S.C. §
2000e-16(c).
8. Defendant is a government body, a political subdivision, created pursuant to the laws
of the State of Oklahoma and is located within this judicial district.
9. Defendant City of Tulsa maintains the Tulsa Fire Department which employs
uniformed firefighters.
10. Defendant City of Tulsa is a person within the meaning of 42 U.S.C. § 2000e(a).
11. Defendant City of Tulsa is an employer within the meaning of Sections 701 of Title
VII and 42 U.S.C. § 2000e.
FACTUALALLEGATIONS
A. Hurt and Lynn's Experiences as Female Firefighters
12. In March, 1998 Hurt became a Tulsa firefighter. She applied for promotions when
eligible. She now holds the position of Chief of Health and Safety.
13. In March 1998, Lynn became a Tulsa firefighter. She applied for promotions when
eligible. She now holds the position of District Chief assigned to District 4.
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14. During their careers as Tulsa firefighters, both Lynn and Hurt were subjected to
numerous incidents of sexual harassment and the tolerance of such harassment by their superiors.
15. In 2020, Hurt and Lynn were the only female firefighters eligible to apply for the
position of Deputy Chief of Field Operations (FD-07).
16. TFD maintains a policy of requiring candidate assessment by an outside agency for
positions designated as FD-06 and FD-07 when more than three (3) candidates apply.
17. In July, 2020 Hurt and Lynn were candidates for the position of Deputy Chief of Field
Operations. Lynn was subjected to pressure from her superiors and other firefighters to withdraw her
name so that, with only three (3) candidates, an outside assessment would not be conducted. Hurt was
not selected. Brent Goins, a less qualified male candidate, was selected and became the Deputy Chief
of Field Operations.
18. Subsequently, Hurt filed a complaint with the Defendant's Human Resources
Department alleging discrimination based on sex. She was at that time the Administrative Chief and
the first female firefighter to hold that position.
19. In March 2021, immediately after that complaint was denied, Hurt was transferred
from her position as Administrative Chief to Chief of Health and Safety, perceived to be a position of
less significance within TFD. Additionally, Hurt was physically relocated to the most remote office
away from the offices of the Fire Chief and executive staff. Further, duties of the new position were
reduced and Hurt was excluded from some of the normal involvement that the position of Chief of
Health and Safety would logically, and did historically, entail.
20. In August 2021 two (2) positions for Assistant Chief (FD-06) were open. Hurt and
Lynn were the only female firefighters qualified to apply and they both applied for each position. Two
(2) male candidates applied for each position. No outside assessments were conducted. There were
four (4) applicants for each position, two (2) male candidates and two (2) female candidates.
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21. On or about August 26, 2021 the two (2) male candidates, who were less qualified
than the two (2) female candidates, were selected for the FD-06 positions.
22. On or about August 29, 2021 Hurt sent a complaint to the City of Tulsa Department
of Human Resources and the Mayor of Tulsa describing the discrimination based on sex which had
occurred in the selection process for the two (2) FD-06 positions. Several days later, Lynn sent a
similar complaint. Hurt was effectively shunned by TFD administrators in retaliation for her
complaint.
23. Actions of the Defendant, described herein, were done with the intention of
discriminating against the Plaintiffs on the basis of their sex.
24. As a result of the retaliation against Hurt, she has experienced high levels of dread,
stress, anxiety, humiliation and other detrimental conditions. The aforementioned and the retaliatory
actions by Defendant constitute an effective termination and Hurt, therefore, submitted her resignation.
25. As a result of the retaliation against Lynn, she has experienced detrimental conditions.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs pray that the Court grant the following relief:
(a) award all appropriate monetary relief, including lost wages and retirement benefits
where applicable, to Hurt and Lynn in an amount to be determined at trial to make each whole for any
loss suffered as a result of the discrimination and retaliation as alleged in this complaint;
(b) award Hurt and Lynn any prejudgment interest on the amount of lost wages and
benefits determined to be due;
(c) award compensatory damages to Hurt and Lynn to fully compensate them for the pain
and suffering caused by Defendant's discrimination and retaliation as alleged in this complaint,
pursuant to and within the statutory limitations of Section I 02 of the Civil Rights Act of 1991, 42
U.S.C. § 1981a;
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(d) enjoin Defendant from further discrimination and retaliation against Plaintiffs and
other female firefighters;
(e) order Lynn to be placed in the next FD-07 position when open;
(f) order Defendant to develop and implement appropriate and effective measures to
prevent discrimination and retaliation, including, but not limited to, implementing appropriate anti-
discrimination and investigation policies and procedures applicable to employees working at TFD, and
implementing adequate training to all employees and officials including, but not limited to: (1) taking
proper steps to investigate incidents of complaints of sexual harassment and sex-based discrimination;
(2) disciplining employees found responsible for sexual harassment; (3) instituting effective anti-
retaliation policies and procedures; (4) disciplining employees found responsible for retaliation; (5)
distributing its anti-harassment and anti-retaliation policies to all employees; (6) implementing a zero-
tolerance policy for sexual harassment and requiring all firefighters and supervisory personnel to
report sexual harassment that they witness, and (7) providing mandatory sexual harassment and anti-
retaliation training for all supervisors and employees;
(g) order any further relief necessary to make Hurt and Lynn whole; and
(h) award such additional relief as justice may require, together with the Plaintiffs'
attorney fees, costs and disbursements in this action.
JURY DEMAND
The Plaintiffs hereby demand a trial by jury of all issues so triable pursuant to Rule 3 8 of the
Federal Rules of Civil Procedure and Section 102 of the Civil Rights Act of 1991, 42 U.S.C. § 1981a.
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Outcome: 06/02/2025 OPINION AND ORDER by Judge John D Russell ; granting in part and denying in part 45 Motion for Summary Judgment (clb, Dpty Clk)

06/09/2025 MINUTE ORDER by Magistrate Judge Paul J Cleary setting Settlement Conference. Plaintiff's Settlement Conference Statement will be due June 30, 2025. Defendant's Settlement Conference Statement will be due July 7, 2025, setting/resetting deadline(s)/hearing(s): ( Settlement Conference set for 7/14/2025 at 10:00 AM before Magistrate Judge Paul J Cleary)

Plaintiff's Experts:

Defendant's Experts:

Comments: