Jones v. Needham, 856 F.3d 1284

Background

Bryan “Shane” Jones worked as a mechanic for Needham Trucking from May–November 2014 and alleged he was fired after refusing sexual advances from his supervisor/shareholder, Julie Needham.
Jones completed an EEOC intake questionnaire (with an attached six‑paragraph statement describing quid pro quo harassment), but the attachment was not included in the formal Charge the EEOC prepared; the Charge recited sexual remarks, complaints to management, and termination.
After receiving a right‑to‑sue letter, Jones sued Needham Trucking and Julie Needham asserting quid pro quo and hostile‑work‑environment Title VII claims plus state tort claims including wrongful interference with a contractual/business relationship.
The district court dismissed the quid pro quo claim for failure to exhaust administrative remedies, dismissed the tort claim as precluded by the Oklahoma Anti‑Discrimination Act (OADA), and dismissed an OESA claim for lack of a private right of action; Jones later voluntarily dismissed his remaining hostile‑work‑environment claim.
On appeal the Tenth Circuit addressed (1) whether the EEOC Charge (not the missing attachment to the intake form) sufficiently exhausted a quid pro quo claim and (2) whether the tortious interference claim was precluded by the OADA.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the EEOC Charge exhausted a quid pro quo Title VII claim	Jones argued the intake questionnaire (including attachment) and Charge together put employer on notice of quid pro quo; strict formality not required if statement describes parties and generally the practices complained of	Needham argued the Charge as submitted lacked the attachment and didn’t put it on notice of a quid pro quo claim, so Jones failed to exhaust	The Charge (checked "Sex," recited sexual remarks and termination) was sufficient to put Needham on notice and to exhaust the quid pro quo claim; court reversed dismissal on exhaustion ground
Whether the intake questionnaire alone constituted the operative charge	Jones urged the intake questionnaire (with attachment) should be treated as the charge	Needham noted the intake questionnaire did not go to the employer and a separate Charge existed	Court treated the formal Charge as the operative document but recognized intake forms can sometimes be charges; here Charge sufficed, so intake form was not controlling
Whether Jones’s tortious interference claim is precluded by the OADA	Jones argued his tort claim was distinct from his statutory discrimination claim and not based solely on discriminatory motive	Needham argued the tort claim arises from same facts and elements substantially overlap with quid pro quo sexual harassment and thus is within OADA’s exclusive remedies	Court held the tortious interference claim is barred by the OADA because its elements substantially overlap with the sex‑discrimination/quid pro quo theory; affirmed dismissal of that claim
Whether to certify question to Oklahoma Supreme Court	Jones moved to certify an OADA question	Needham opposed certification	Court denied motion to certify

Key Cases Cited

Meritor Sav. Bank v. Vinson, 477 U.S. 57 (recognizing sexual harassment as sex discrimination under Title VII)
Burlington Indus. v. Ellerth, 524 U.S. 742 (distinguishing quid pro quo/tangible employment action and hostile work environment)
Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (administrative exhaustion requirement for Title VII claims)
Fed. Express Corp. v. Holowecki, 552 U.S. 389 (when an intake questionnaire can constitute an EEOC charge)
Occidental Life Ins. Co. of Cal. v. EEOC, 432 U.S. 355 (role of the EEOC charge in notifying employers)
Jones v. UPS, Inc., 502 F.3d 1176 (10th Cir.) (scope of administrative charge and expected EEOC investigation)
Pinkerton v. Colo. Dep’t of Transp., 563 F.3d 1052 (10th Cir.) (quid pro quo terminology and elements)
Tufty’s, Inc. v. City of Okla. City, 212 P.3d 1158 (Okla.) (elements of tortious/malicious interference)