Jiang v. City of Tulsa

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 17, 2026
Docket25-5097
StatusPublished

This text of Jiang v. City of Tulsa (Jiang v. City of Tulsa) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jiang v. City of Tulsa, (10th Cir. 2026).

Opinion

Appellate Case: 25-5097 Document: 29-1 Date Filed: 03/17/2026 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS March 17, 2026 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

HUA JIANG,

Plaintiff - Appellant,

v. No. 25-5097

CITY OF TULSA,

Defendant - Appellee. _________________________________

Appeal from the United States District Court for the Northern District of Oklahoma (D.C. No. 4:23-CV-00255-CVE-CDL) _________________________________

Mark A. Smith of Caruso & Smith, PLLC, Tulsa, Oklahoma (Daniel E. Smolen of Smolen & Roytman, PLLC, Tulsa, Oklahoma, with him on the briefs), for Plaintiff-Appellant.

Hayes T. Martin, Assistant City Attorney (Jack C. Blair, City Attorney, and R. Lawson Vaughn, Senior Assistant City Attorney with him on the brief), Tulsa, Oklahoma, for Defendant-Appellee. _________________________________

Before MATHESON, PHILLIPS, and ROSSMAN, Circuit Judges. _________________________________

PHILLIPS, Circuit Judge. _________________________________

When he applied to be the superintendent of Tulsa’s A.B. Jewell water-

treatment plant, Hua Jiang was an accomplished engineer. But the city wanted Appellate Case: 25-5097 Document: 29-1 Date Filed: 03/17/2026 Page: 2

someone with leadership experience. And Jiang, a middle-aged man from

China, didn’t have any. So the city hired a younger, white candidate who did.

In the process, the city violated its written hiring policies. Those policies

required the city to hire someone with a college degree in biology, engineering,

environmental sciences, or a related field. Yet the hired candidate didn’t have a

degree at all. Jiang reported the city’s error to its civil-service commission,

which confirmed that the city had violated its policies.

In response, the city removed the job posting’s degree requirement to

reflect the city’s customary practice of substituting experience for education.

The city then redid its hiring. The same three people applied, and, again, the

city hired the candidate with more leadership experience.

Jiang sued the city for discrimination. He alleged that the reason the city

didn’t choose him for superintendent was his age and race. Though the city had

said that it wanted a candidate with more leadership experience, Jiang argued

that this justification was pretext for the city’s discriminatory animus. He also

argued that the city removed the degree requirement to retaliate for his

reporting discrimination.

At summary judgment, Jiang pointed to his superior qualifications, the

city’s subjective hiring process, and the procedural shortcuts the city took to

hire its preferred candidate. But Jiang didn’t point to facts upon which a jury

could find that the city was untruthful about valuing a candidate with

2 Appellate Case: 25-5097 Document: 29-1 Date Filed: 03/17/2026 Page: 3

leadership experience. So the district court granted summary judgment to the

city.

Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

BACKGROUND

I. Factual Background

We present the facts in the light most favorable to Jiang, the nonmoving

party. See Deherrera v. Decker Truck Line, Inc., 820 F.3d 1147, 1151 n.1 (10th

Cir. 2016).

When he sued, Jiang was a senior engineer at Tulsa’s A.B. Jewell water-

treatment plant. Jiang was born in China and speaks English with a Chinese

accent. He holds a Ph.D. in engineering, and though he excelled in his job,

outside contractors sometimes complained that he was hard to work with.

By 2021, Jiang had worked for Tulsa’s water department for over a

decade. During that time, he applied to many managerial positions. He did so

because he wanted managerial experience: outside of coaching a water-

department quiz-bowl team, Jiang hadn’t supervised anyone except a temporary

employee and a few interns. And he thought moving to a managerial role could

position him to one day run the department. Yet every time he applied for a

managerial role, the city picked a white candidate instead.

In June 2021, when Jiang applied to be A.B. Jewell’s superintendent, it

happened again. The city picked one of the two younger, white men who had

also applied. Dylan Hutchcraft, the eventual pick, was an operations supervisor

3 Appellate Case: 25-5097 Document: 29-1 Date Filed: 03/17/2026 Page: 4

at one of Tulsa’s other water-treatment plants. In that role, he oversaw multiple

employees. And years before, while deployed in Afghanistan with the National

Guard, he had served as a squad leader. John Curry, the other applicant, was an

A.B. Jewell maintenance supervisor who led a team of ten.

The hiring process began uneventfully. The city followed its familiar

two-step procedure. First, the city’s personnel director certified Jiang,

Hutchcraft, and Curry as being qualified for the position. The personnel

director gave that list of candidates to Stefanie Hunter, the hiring manager for

the position.

Second, Hunter decided whom to hire from the certified applicants.

Though she had ultimate hiring authority, she convened a panel to interview

and evaluate the candidates. That panel consisted of Hunter and two other

senior water-department employees. The panel interviewed Jiang, Hutchcraft,

and Curry, asking the same questions of each and grading under a uniform

matrix. One panelist ranked Hutchcraft first, Jiang second, and Curry third. The

other two ranked Hutchcraft first, Curry second, and Jiang third. After

concluding that Hutchcraft had the best mix of technical knowledge and

leadership experience, Hunter hired him.

Then the process took a turn. When Jiang found out that Hutchcraft was

hired over him, he complained of race and age discrimination to the city’s

human-resources department. According to Jiang, the personnel director

shouldn’t have certified Hutchcraft and Curry as applicants, as neither met the

4 Appellate Case: 25-5097 Document: 29-1 Date Filed: 03/17/2026 Page: 5

job’s education requirement. The human-resources department denied Jiang’s

grievance, and Jiang appealed to the city’s civil-service commission.

For good reason, the civil-service commission agreed with Jiang. To

start, the city had recently revised the minimum requirements for the treatment-

plant-superintendent position. Those revisions preserved an education

requirement: “a bachelor’s degree in engineering technology,

environmental/biological sciences, or a related field.” App. vol. II at 566. And

even though the position also permitted “an equivalent combination of training

and experience,” id., that option didn’t apply. Why? Because, for positions

requiring a specific degree, the city’s written policy prohibited substituting

experience for education. Neither Hutchcraft nor Curry had a college degree,

let alone one in engineering or biology. Thus, according to the city’s written

policy, the personnel director never should have certified them. The civil-

service commission told the city to “go back and follow” its policies. App. vol.

III at 803.

So the city rewrote the position’s education requirement. Put bluntly, the

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