HomeMy WebLinkAbout2024-cv-2336 - O’Ryan v. City of Fort Collins - 001 - Complaint, Summons, CCSIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Case No. 24-cv-__
LAURELEI O’RYAN,
Plaintiff,
vs.
CITY OF FORT COLLINS,
Defendant.
COMPLAINT AND JURY DEMAND
Plaintiff Laurelei O’Ryan, by her attorney Robert M. Liechty, brings her complaint
as follows:
1. Defendant City of Fort Collins has a water treatment department which is
composed of four sections (operators, maintenance, lab, and water resources) with
approximately 22-23 employees. Of these employees, only two were female during the
pertinent time, plaintiff Laurelie O’Ryan and Kathleen Ganzer, who ran the lab. Plaintiff
worked in the water treatment department for five years from May, 2018, through her
termination on June 15, 2023.
2. Plaintiff alleges that she was terminated because of gender discrimination and
retaliation for complaining of gender discrimination. She filed a complaint of
discrimination and retaliation with Colorado’s Civil Rights Division and received a right
Case No. 1:24-cv-02336-MEH Document 1 filed 08/23/24 USDC Colorado pg 1 of 10
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to sue letter dated May 28, 2024. She has timely filed her complaint in this court, which
has jurisdiction and venue over her complaint under Title VII.
3. Ms. O’Ryan received an associates degree in water quality management from
Red Rocks Community College in 2013. She has been a certified water treatment
operator for approximately 10 years. She interned at the City of Louisville and Aurora
water departments. The Aurora water department is considered one of the best water
departments in the nation.
4. Towards the end of 2017, Tyler Wells, Colby Groves, and plaintiff applied for a
water treatment operator position with the City. Mr. Wells, who had worked as an
operator for the department before, was hired and plaintiff does not challenge his hire.
Plaintiff asked that she be considered for the next opening.
5. Mr. Groves had already been working for the City as a utility maintenance
operator, a position lower than a water treatment operator.
6. In May, 2018, the department promoted Mr. Groves to a water treatment operator
position, without informing plaintiff that this position was open, because the department
did not want to explain why it did not hire plaintiff. Mr. Groves had a D certification,
while plaintiff had an A certification. Plaintiff had two years experience as an operator
and Mr. Groves had no experience.
7. Instead of informing plaintiff of the open operator position, the City offered
plaintiff Mr. Grove’s old position as utility maintenance operator. Plaintiff accepted this
offer even though it was beneath her experience and certification level.
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8. In approximately January, 2019, the City had an open water treatment operator
position, for which plaintiff applied. However, the City pushed back the hiring of this
position for five months to try to obtain more A-certified operators to compete with
plaintiff for the position. At the time that the City promoted plaintiff to the operator
position, in June, 2019, there were three openings and plaintiff was the only A-certified
operator who was hired into any of the positions.
9. Jeff Monson, a lead operator who sat on plaintiff’s above June hiring panel, said
that he did not think that women could do the job of water treatment operator. Gregg
Stonecipher, who was on the same hiring panel, told plaintiff that he noticed that plaintiff
was being discriminated against in the interview process. He also asked Deb
Mossberg, in human resources, if she noticed it. She did, but, because plaintiff was
promoted to the operator position, nothing came of this.
10. Towards the end of 2019, plaintiff’s then-lead operator, Dale Schnathorst,
recommended that plaintiff be promoted to the next highest level within her position ,
contingent upon the completion of two tasks.
11. Shortly thereafter, in approximately November, 2019, Tyler Wells was promoted
to lead operator and he became plaintiff’s supervisor. He said that in order for plaintiff
to be promoted, she had to complete more tasks than that required by Mr. Schnathorst,
and possibly a third list of tasks, before she could receive the promotion. No male was
required to jump through such hoops. Plaintiff complained to HR who noted that this
was moving the bar she had to clear to receive the promotion.
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12. Plaintiff and Mr. Wells discussed this matter on January 9, 2020. Plaintiff was
upset about the extra requirements put on her, and not on the male employees, and
vigorously contested what Mr. Wells was doing to her. Plaintiff was not disciplined nor
written up for this disagreement on January 9, although she was given a poor QPA
(Quarterly Performance Alignment) for the next quarter because she had challenged Mr.
Wells.
13. In early 2020, Ken Morrison, plaintiff’s next level supervisor above Mr. Wells, said
that he wanted to delay the level promotions for the operators. However, the only
operator to which he delayed such a promotion was plaintiff. In fact, both Casey
Blosser and Erik Monahan later moved up immediately when they obtained their A
certifications.
14. Mark Kempton, the department director, met with all his employees , believed to
be in 2021, following a survey done of the department. In plaintiff’s meeting with him,
she complained to him of the gender discrimination that she observed. Her complaint
had no effect.
15. Gregg Stonecipher was promoted to the department’s director position in
approximately August-September, 2022. The only other woman in the department,
Kathleen Ganzer, applied for his vacant position as head of the lab. She had been the
lab’s lead chemist for 30 years. In approximately November, 2022, the City gave the
job to Erik Monahan, who had 3½-years experience in the water treatment department
and only some part-time work experience in the lab as an intern.
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16. Plaintiff was told Ms. Ganzer was not given the promotion because she provided
too much detail in her interview.
17. Also in November, 2022, plaintiff applied for a lead operator position. The City
gave the position to Casey Blosser. Mr. Blosser had only recently obtained an A
certification, while plaintiff had had her A certification for five years. Plaintiff had a
degree in water quality management and had substantially more experience in water
treatment than did Mr. Blosser.
18. In the interview for this promotion, plaintiff proposed numerous ideas for
improvements. After she was passed over for the promotion, when the City gave the
promotion to Mr. Blosser, Ken Morrison, plaintiff’s supervisor, said that the department
still wanted to implement her ideas. That is, the department would use her ideas, but it
would not advance her in her career.
19. Plaintiff asked both her lead operator, Tyler Wells, and her new department
head, Gregg Stonecipher, why she was not given the promotion to lead operator. Both
separately told her that Mr. Blosser did better in his interview in answering technical
questions. Plaintiff alleges that he was coached regarding the answers to the technical
questions.
20. When Jeff Monson was promoted to a lead position in 2018, everyone knew that
he was the least technically skilled applicant for the position. When Colby Groves was
hired as an operator, he said that during his interview he could not even remember for
what chlorine was used. On the other hand, plaintiff was told that Ms. Ganzer was too
detailed in answering the technical questions.
Case No. 1:24-cv-02336-MEH Document 1 filed 08/23/24 USDC Colorado pg 5 of 10
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21. Mr. Wells told plaintiff that work experience with the City did not matter in the
promotion of Mr. Blosser. Nonetheless, Mr. Wells also said that Mr. Blosser had better
experience than plaintiff because he worked the day shift. In fact, plaintiff had far more
experience than did Mr. Blosser.
22. In November-December, 2022, plaintiff was still upset that neither she nor Ms.
Ganzer had been promoted. She complained separately both to Mr. Wells (three times)
and to Mr. Stonecipher (once) that she thought women were treated differently than
men in the department. City policy required that they report plaintiff’s complaints to
human resources, but they did not.
23. On Thursday, January 5, 2023, at approximately 6:30 a.m., just before the end of
plaintiff’s night shift, Tyler Wells came on duty and started small talk with plaintiff i n the
secondary control room. Plaintiff tried to avoid him because she was still upset over the
fact that neither she nor Ms. Ganzer had been promoted and she was upset over the
excuses given to justify these actions.
24. Mr. Wells asked plaintiff, “Why are you being like this?” to which plaintiff replied
that she was still upset about how women were treated in the department. She also
said, “You should be scared about how bad this looks.” Mr. Wells alleges that he then
asked plaintiff, “Are you threatening me?” to which he claims that plaintiff said that she
was threatening him. Plaintiff did not threaten him.
25. Instead, plaintiff said, “That’s not a threat. How can you even call that a threat?”
Mr. Wells wrote two emails on January 5 to plaintiff within an hour after the alleged
threat. In neither email did he say that he felt physically threatened.
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26. After the above discussion on January 5, Mr. Wells left the control room, crossed
a landing, went down the stairs, and was on the lower floor approximately 10-15 feet
from plaintiff when she slammed the control-room door closed.
27. Plaintiff was suspended on the next day, January 6, 2023, and never returned to
work.
28. On January 17, 2023, plaintiff sent an email to Gregg Stonecipher stating that
she was upset because less experienced males were consistently getting promotions
over more experienced women. She also noted that the justifications for these
promotions kept changing, which she had brought up with several managers over
several years to no avail.
29. On January 23, 2023, Mr. Wells wrote a recommendation to terminate plaintiff
based upon the argument that happened on January 5 and also what happened in
January, 2020, referenced in ¶ 12 above.
30. Because plaintiff had complained of gender discrimination and retaliation, the
City obtained a third party to investigate the complaint prior to plaintiff’s termination.
The City refused to release that investigation to plaintiff , but she was told that the third
party found no evidence of discrimination or retaliation.
31. On June 15, 2023, Jeremy Woolf, the senior director of integrated water
operations, approved the recommendation to terminate. Plaintiff was terminated for
violating two personnel policies (1) for "abusive or threatening treatment of any person"
and (2) for “threats and violence."
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32. Mr. Woolf found the following: plaintiff “told Mr. Wells, ‘you should be scared.’ I
believe any reasonable person would perceive this as a threat to their personal safety,
as Mr. Wells has. I also believe I have a responsibility to avoid placing Mr. Wells or
others at risk, and your own words indicate you pose this risk.” This finding is not
believable.
33. Plaintiff was 54 years old and stands 5’2” tall. Mr. Wells was approximately 37
years old and stands over 6 feet tall. It is not credible that anyone would believe that
Mr. Wells would have felt physically threatened by plaintiff. Nonetheless, that was the
excuse used to terminate plaintiff.
34. Furthermore, such talk is typical in the department and goes without punishment
for the males. In 2019, Zach Gilbert and Jeff Monson were involved in a heated verbal
fight in the control room. Neither was terminated and Mr. Monson was even promoted
soon thereafter.
35. Prior to 2018, Dale Schnathorst lost his temper because the City had installed
surveillance cameras. He dropped his trousers and “mooned” a camera, he gave the
middle finger to a camera, and he broke a piece off one of the cameras. He then
slammed a door open so that the handle made a hole in the wall which had to be
patched with a metal plate. He was not disciplined but, instead, was sent to anger
management classes and later promoted.
36. John Grimm had a long-standing habit of sleeping between 12:00 and 4:00 a.m.
on every shift. Although this was well known, he was never talked to about it nor
disciplined.
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37. Mr. Grimm also had a history of losing his temper, throwing books, and raising
his voice at supervisors. He suffered no consequences because of his outbursts.
38. Kyle Holmes, an operator, had a heated argument in the break room, but
suffered no consequences. This occurred prior to plaintiff’s employment. He said that
he observed that women were treated differently than were men.
Claim of Discrimination
39. The City discriminated against plaintiff’s sex when it failed to hire her in May,
2018, as a water treatment operator, as stated in ¶ 6 above. Second, it discriminated
against her in delaying her level promotion as described in ¶ 8 above. Third, it
discriminated her against her in November, 2022, when it failed to promote her to the
lead operator position as referenced in ¶ 17 above. Finally, it discriminated against her
by terminating her employment on June 15, 2023.
40. But for the fact that plaintiff was a woman, she would have received these
promotions and would not have been terminated. This failure on the part of the City
violates Title VII, 42 USC §2000e-2a.
41. As a result of this violation, plaintiff has suffered lost wages and emotional
damages and is entitled to recovery under §2000e-5(g) and 42 USC §1981A(b)(3).
42. She is also entitled to her attorney’s fees under §2000e-5(k).
Claim of Retaliation
43. But for the fact that plaintiff complained of sexual discrimination on multiple
occasions to multiple people in the City, plaintiff would not have been terminated. This
retaliation violates plaintiff’s rights under 42 USC §2000e-3.
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44. As a result of this termination, plaintiff is entitled to damages under 42 USC
§2000e-5(g) and 42 USC §1981A(b)(3).
45. She is also entitled to her attorney’s fees under §2000e-5(k).
WHEREFORE, plaintiff Laurelei O’Ryan respectfully requests that this court enter
judgment in her favor and for costs, interest, attorney’s fees, and such other relief as
this court may deem proper.
Plaintiff requests trial to a jury.
Respectfully submitted this August 23, 2024.
By: s/ Robert M. Liechty
Robert M. Liechty
ROBERT M LIECHTY PC
1800 Gaylord St.
Denver, Colorado 80206
Tel: (303) 861-5300
Fax: (303) 861-2746
Email: rliechty@crossliechty.com
Courtesy copy:
City Attorney Carrie Daggett, via email
Case No. 1:24-cv-02336-MEH Document 1 filed 08/23/24 USDC Colorado pg 10 of 10
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case No. 1:24-cv-02336-MEH Document 1-1 filed 08/23/24 USDC Colorado pg 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date).
’I personally served the summons on the individual at (place)
on (date); or
’I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date), and mailed a copy to the individual’s last known address; or
’I served the summons on (name of individual), who is
designated by law to accept service of process on behalf of (name of organization)
on (date); or
’I returned the summons unexecuted because ; or
’Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case No. 1:24-cv-02336-MEH Document 1-1 filed 08/23/24 USDC Colorado pg 2 of 2
JS 44 (Rev. 03/24)CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I.(a) PLAINTIFFS DEFENDANTS
(b)County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
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and One Box for Defendant) (For Diversity Cases Only)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party)Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III)of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6
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CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
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150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
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of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
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190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
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Appellate Court
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Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
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COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
DEMAND $CHECK YES only if demanded in complaint:
JURY DEMAND:Yes No
VIII. RELATED CASE(S)
IF ANY (See instructions):JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
26 USC 7609
INTELLECTUAL
RE OF ATTORNEY OF RECORD
Case No. 1:24-cv-02336-MEH Document 1-2 filed 08/23/24 USDC Colorado pg 1 of 2
Larimer
Laurelie O'Ryan
Robert Liechty, 1800 Gaylord St, Denver, CO 80206
303-319-8382
City of Ft. Collins
✖
✖
Title VII, 42 USC section 2000e
sex discrimination and retaliation
✖
8/23/2024
JS 44 Reverse (Rev. 03/24)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b)County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
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in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
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Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
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precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
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that is most applicable. Click here for: Nature of Suit Code Descriptions.
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PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statute.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
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Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
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VIII. Related Cases. This section of the JS 44 is used to reference related cases, if any. If there are related cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case No. 1:24-cv-02336-MEH Document 1-2 filed 08/23/24 USDC Colorado pg 2 of 2