Hauck v. Putnam City Independent School District I001, 5:20-cv-00390

Plaintiff Adrienne Hauck, an assistant principal, alleges she was denied promotion to principal four times (May 2017, March 2018, April 2019, May 2019) because of her gender, sexual orientation, and failing to conform to gender stereotypes.
Hauck sued Putnam City Independent School District under Title VII and the Oklahoma Anti-Discrimination Act (OADA).
Defendant moved to dismiss: arguing (a) Title VII claims based on 2017–2018 promotions are time-barred, (b) Title VII does not cover sexual-orientation discrimination, and (c) Hauck’s OADA claim is barred by failure to satisfy the Oklahoma Governmental Tort Claims Act (GTCA) notice requirements.
Hauck narrowed her Title VII claims in briefing, limiting them to the April and May 2019 promotion decisions, rendering the challenges to 2017–2018 promotions moot.
After briefing, the U.S. Supreme Court decided Bostock, holding Title VII prohibits discrimination because of homosexuality or transgender status, undermining the defendant’s argument on sexual-orientation coverage.
The court concluded the complaint fails to plead GTCA notice compliance for the OADA claim (finding post-Duncan amendments bring OADA claims within GTCA’s scope), granted leave to amend to show compliance, and gave Hauck ten days to file an amended complaint or face dismissal without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Title VII claims based on 2017–2018 promotions survive	Hauck explained earlier denials were background and limited claims to 2019 decisions	2017–2018 claims are time-barred for failure to timely file EEOC charges	Moot as to 2017–2018 because Hauck narrowed her claims to 2019 promotions
Whether Title VII covers sexual-orientation / gender-stereotype discrimination	Hauck contends Title VII prohibits discrimination for sexual orientation and gender stereotyping	Medina suggests Tenth Circuit previously excluded sexual orientation from Title VII protection	Bostock controls: Title VII covers discrimination because of homosexuality, transgender status, and sex-stereotyping; claim survives dismissal
Whether OADA claims are subject to GTCA pre-suit notice	Hauck argues OADA claims need not satisfy GTCA notice or, alternatively, she can amend to show she complied	Putnam City contends GTCA bars OADA claims absent statutory notice compliance	Court follows post-Duncan statutory developments and case law treating OADA claims as subject to GTCA notice; dismissal without prejudice unless Hauck amends to plead GTCA compliance within 10 days

Bostock v. Clayton County, 140 S. Ct. 1731 (superseding precedent on Title VII coverage for sexual orientation and transgender status)
Medina v. Income Support Div., 413 F.3d 1131 (10th Cir. 2005) (pre-Bostock Tenth Circuit treatment of sexual-orientation claims)
Duncan v. City of Nichols Hills, 913 P.2d 1303 (Okla. 1996) (Oklahoma Supreme Court on interaction of OADA notice and GTCA)
Tuffy's Inc. v. City of Okla. City, 212 P.3d 1158 (Okla. 2009) (GTCA is exclusive remedy for tort claims against governmental entities)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to presumption of truth)
Burnett v. Mortg. Elec. Registration Sys., Inc., 706 F.3d 1231 (10th Cir. 2013) (standard for accepting well-pleaded allegations on Rule 12(b)(6))
U.S. ex rel. Stone v. Rockwell Int'l Corp., 282 F.3d 787 (10th Cir. 2002) (leave to amend policy)