Jones v. City of Dallas, Texas, 24-10803

Jacqueline Jones, an African-American woman and disabled veteran, worked for the City of Dallas for nearly 20 years, most recently as a Senior Contract Compliance Administrator and then as a Contracts Solutions Specialist.
Jones alleged that after reassignment to her latest role, she was paid less than a white colleague, Lori Davidson, who had additional qualifications and responsibilities.
Jones filed a charge with the EEOC alleging racial discrimination, unequal pay under Title VII, and disability discrimination and retaliation under the ADA; she received a right-to-sue letter.
Jones’s prior lawsuit against the City (Jones I) ended in a jury verdict for the City.
The district court granted summary judgment to the City, finding Jones had failed to exhaust administrative remedies for all claims except the unequal pay claim; for the latter, Jones allegedly failed to establish a prima facie case.
On appeal, the Fifth Circuit reviewed exhaustion and substantive issues, ultimately affirming the district court’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies	Jones claimed she had sufficiently exhausted her Title VII and ADA claims through her EEOC charge.	City argued Jones only exhausted the Title VII unequal pay claim, not others.	Jones forfeited review; failure to raise issues timely.
ADA failure to accommodate	Jones argued the EEOC was on notice of her ongoing requests for accommodation.	City asserted Jones's charge lacked sufficient specifics about accommodation requests.	Jones failed to exhaust; claim dismissed.
ADA retaliation	Jones claimed her termination was retaliation for seeking accommodations.	City noted Jones did not provide specific facts or identify retaliation in her EEOC filing.	Claim not specifically exhausted or challenged; dismissed.
Title VII unequal pay	Jones argued Davidson was a similarly situated comparator for the pay disparity claim.	City argued Davidson’s duties, qualifications, and circumstances differed materially.	No appropriate comparator; no prima facie case; claim dismissed.

Sanchez v. Standard Brands, Inc., 431 F.2d 455 (5th Cir. 1970) (exhaustion requires factual specificity for EEOC investigation)
Taylor v. United Parcel Serv., Inc., 554 F.3d 510 (5th Cir. 2008) (establishing prima facie case for pay discrimination under Title VII)
Badgerow v. REJ Props., Inc., 974 F.3d 610 (5th Cir. 2020) (comparator must have nearly identical employment circumstances)
Mitchell v. Mills, 895 F.3d 365 (5th Cir. 2018) (burden-shifting for pay disparity claims)
Ortiz v. City of San Antonio Fire Dep’t, 806 F.3d 822 (5th Cir. 2015) (plain error review when party fails to object to magistrate findings)