Kimbro v. Oklahoma House of Representatives

CourtDistrict Court, W.D. Oklahoma
DecidedJanuary 16, 2025
Docket5:22-cv-01003
StatusUnknown

This text of Kimbro v. Oklahoma House of Representatives (Kimbro v. Oklahoma House of Representatives) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kimbro v. Oklahoma House of Representatives, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

AMARI KIMBRO, ) ) Plaintiff, ) v. ) ) Case No. CIV-22-1003-PRW STATE OF OKLAHOMA ex rel. ) OKLAHOMA HOUSE OF ) REPRESENTATIVES, ) ) Defendant. ) ORDER Before the Court is Defendant State of Oklahoma ex rel. Oklahoma House of Representatives’ Motion for Summary Judgment (Dkt. 25). This matter is fully briefed, and for the reasons that follow, the Motion (Dkt. 25) is GRANTED. Background1 This case arises from alleged racial discrimination and retaliation. Plaintiff Amari Kimbro was employed as a Legislative Assistant for the Oklahoma House of Representatives (the “House”) from January 22, 2019, until her employment was terminated on June 2, 2021. Throughout her employment with the House, several performance issues were documented. In November of 2019, Representative Regina Goodwin, one of Kimbro’s assigned representatives, submitted a long and detailed list of complaints about Kimbro’s performance to the human resources manager at the time.

1 This section is based on the undisputed facts as described in the parties’ briefs. Kimbro was subsequently reassigned to two different representatives. In December of 2019, the Legislative Assistant Supervisor and Parliamentarian at the time, C.J. Calvin,

sent her an email informing her that it was improper for her to take time off without first following the proper procedure for taking time off, that it was improper for her to consistently submit late time sheets, and that some time that she had submitted working offsite was expressly disallowed by House policy. In October of 2020, Jason Sutton, the Director of Operations and Administration for the House, investigated Kimbro (and others) for timecard theft. At some point not specified by the parties, a constituent of

Representative Jason Lowe left a voicemail for Sutton, complaining of Kimbro’s attitude and lack of professionalism during a conversation with the constituent. And finally, on April 21, 2021, Kimbro was perceived to be involved in an unlawful protest that took place during a legislative session of the House. Some of the details surrounding the protest are relevant to this action. On April 21,

2021, protestors supporting the Black Lives Matter movement entered the gallery of the House while a legislative session was taking place on the floor. The protestors shouted profanities and obscenities, so they were asked to leave due to the interruption of the ongoing session. Kimbro left her office to watch and proceeded to take a video of the protest. When the protest escalated, Kimbro approached some of the protesters, referring

to them by name, and asked them to leave. Kimbro then posted the video that she had recorded onto her Facebook page and tagged an organizer of the protest in her post, all while on the clock. Kimbro was terminated on June 2, 2021. Following her termination, Kimbro filed a charge with the Equal Employment Opportunity Commission alleging that the House

discriminated and retaliated against her based on her race. Upon the EEOC’s issuance of a right-to-sue letter, Kimbro filed suit against the House, alleging race discrimination and retaliation in violation of Title VII, 42 U.S.C. § 1981, and Oklahoma public policy (See Dkt. 1). The House now moves for summary judgment on Kimbro’s claims. Legal Standard Rule 56(a) of the Federal Rules of Civil Procedure requires “[t]he court [to] grant

summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” In considering a motion for summary judgment, a court must view all facts and reasonable inferences in the light most favorable to the nonmovant.2 Courts are not to weigh the evidence and determine the truth of the matter asserted, but instead are to determine only whether there is a genuine dispute

for trial before the fact-finder.3 A fact is “material” if, under the substantive law, it is essential to the proper disposition of the claim.4 A dispute is “genuine” if there is sufficient evidence on each side so that a rational trier of fact could resolve the issue for either party.5 When, as here, the nonmoving party has the ultimate burden of persuasion at trial, the moving party “has both the initial burden of production on a motion for summary

2 Adler v. Wal-Mart Stores, Inc., 144 F.3d 664, 670 (10th Cir. 1998) (citations omitted). 3 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). 4 Id. at 248. 5 Id. judgment and the burden of establishing that summary judgment is appropriate as a matter of law.”6 “The moving party may carry its initial burden either by producing affirmative

evidence negating an essential element of the nonmoving party’s claim, or by showing that the nonmoving party does not have enough evidence to carry its burden of persuasion at trial.”7 “Once the moving party points out the absence of evidence to create a ‘genuine issue’ of a ‘material fact’ on which the non-moving party bears the burden of proof at trial, . . . [t]he non-moving party must set forth specific facts showing there is a genuine issue for trial.”8

Analysis I. Section 1981 Claim Kimbro first alleges that the House discriminated and retaliated against her based on her race in violation of 42 U.S.C. § 1981. But “§ 1981 does not provide a vehicle for remedying racial discrimination and retaliation in cases brought against state actors.”9

Instead, such claims must be brought under § 1983.10 Because the House is a state agency, Kimbro’s claims under § 1981 against it are not permissible as a matter of law.

6 Trainor v. Apollo Metal Specialties, Inc., 318 F.3d 976, 979 (10th Cir. 2002), as amended on denial of reh’g (Jan. 23, 2003) (citing Nissan Fire & Marine Ins. Co. v. Fritz Cos., 210 F.3d 1099, 1102 (9th Cir. 2000)). 7 Id. 8 Otis v. Canadian Valley-Reeves Meat Co., 884 F. Supp. 446, 449–50 (W.D. Okla. 1994), aff’d, 52 F.3d 338 (10th Cir. 1995) (citing Anderson, 477 U.S. at 248). 9 Hannah v. Cowlishaw, 628 F. App’x 629, 632 (10th Cir. 2016) (unpublished) (citing Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701, 705, 735 (1989)). 10 Jett, 491 U.S. at 735 (“We hold that the express ‘action at law’ provided by § 1983 for the ‘deprivation of any rights, privileges, or immunities secured by the Constitution and In response, Kimbro suggests that the Court should grant her leave to amend this claim to one brought under § 1983, citing Bolden v. City of Topeka.11 But a response to a

motion for summary judgment is not the proper vehicle for requesting leave to amend a pleading.12 And even if Kimbro had properly requested leave to amend, such amendment would be futile. States—and state agencies—are entitled to sovereign immunity13 unless Congress has abrogated the states’ immunity, or the state has waived it.14 The Supreme Court has held that § 1983 did not abrogate states’ sovereign immunity,15 and states are not “persons” under § 1983.16 Further, Oklahoma has not waived its sovereign immunity for §

1983 claims.17 As such, even if Kimbro were granted leave to amend her complaint to

laws,’ provides the exclusive federal damages remedy for the violation of the rights guaranteed by § 1981 when the claim is pressed against a state actor.”). 11 441 F.3d 1129 (10th Cir. 2006).

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Kimbro v. Oklahoma House of Representatives, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kimbro-v-oklahoma-house-of-representatives-okwd-2025.