Plaintiff Lashaila Gates sued defendant Oklahoma Health and Wellness Center in the United States District Court for the Western District of Oklahoma, raising claims of race discrimination and hostile work environment under Title VII and the Oklahoma Anti-Discrimination Act (OADA). Defendant Oklahoma Health and Wellness Center moved to dismiss plaintiff’s claims under Rule 12(b)(6).
Factual Overview
Gates, an African-American female, was employed as a chiropractic assistant by the defendant, owned by Dr. Douglas Cook, a white male. Gates alleged she experienced discriminatory treatment, including sexual harassment by a client that was dismissed by Dr. Cook. She also claimed Dr. Cook made inappropriate racial comments, including claiming African heritage, using racial stereotypes, and making derogatory statements about the Black Lives Matter movement.
Gates further alleged pay disparities between herself and white employees, reduction of her work hours, and witnessing the termination of another African-American employee. She claimed she was constructively discharged on February 8, 2021, after seeing Dr. Cook had “liked” a Facebook comment containing a racial slur.
Legal Analysis
Title VII Claims
Race Discrimination – Disparate Treatment: The court found that Gates adequately alleged an adverse employment action through her claim of constructive discharge. The court determined that Gates’ allegations of offensive discriminatory conduct and her resignation were sufficient to state a claim for constructive discharge at the pleading stage.
The court also found that Gates plausibly alleged other adverse employment actions, including delays in receiving raises and reductions in work hours, which the court deemed more than mere inconveniences or alterations of job responsibilities.
Race Discrimination – Hostile Work Environment: The court concluded that Gates adequately pled that the defendant’s conduct was objectively severe and pervasive. The court noted that Gates alleged numerous discriminatory incidents within a two-year period, which plausibly supported a finding of a workplace permeated with discriminatory intimidation, ridicule, and insult.
OADA Claim: The court applied the same analysis to Gates’ OADA claim as it did to her Title VII claims, noting that OADA claims are analyzed similarly to Title VII claims.
The court denied the defendant’s motion to dismiss for all of Gates’ claims under both Title VII and the OADA.
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