25 Okla. Stat. § 1101
Purpose and remedies of the Oklahoma Anti-Discrimination Act: the cases that interpreted this section
73 citing cases reviewed of 92 in the citation index: 13 interpreted the section (annotated below), 60 cited it only in passing. Cases filed after 2025-12-23 may not have been reviewed yet.
Have a situation under 25 Okla. Stat. § 1101?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Purpose and interpretation
Law changed since The 2011 OADA amendments removed § 1101(A)'s express reference to federal civil rights law; this opinion interpreted the former purpose clause, as Hauck v. Putnam City Independent School District I001 — cluster 9923244 — filed 2022-08-24, explains.
Section 1101(A)’s statement of purpose does not make the federal Rehabilitation Act’s sole factor standard the standard for Oklahoma employment discrimination claims.
Bentley v. Cleveland County Board of County Commissioners ex rel. Cleveland County · filed 1994-11-29(A)
There is no question the state legislature sought to adopt the same policies intended under the Rehabilitation Act in preventing discrimination in the work place. However, under Oklahoma law, the legislative intent must be ascertained from the language of the pertinent statute. ... If the Oklahoma legislature wanted to adopt the federal standard it could have easily done so by adding the word “solely” to the statute. It did not do so.Read the full opinion on CourtListener →
Law changed since The 2011 OADA amendments removed § 1101(A)’s express reference to federal civil rights law, as Hauck v. Putnam City Independent School District I001 explains; this opinion interpreted the former purpose clause.
Section 1101(a) identifies implementing Title VII in Oklahoma as a purpose of the Oklahoma Anti-Discrimination Act, so the Act is interpreted together with Title VII when determining an employee’s rights under state law.
Marshall v. OK Rental & Leasing, Inc. · filed 1997-03-18(a)
One of the expressed purposes of Oklahoma’s anti-discrimination statute was to implement the provisions of Title VII into the State of Oklahoma. ... List teaches that we must therefore interpret Oklahoma’s anti-discrimination statute together with Title VII in order to determine an employee’s rights under state law.Read the full opinion on CourtListener →
Law changed since The 2011 OADA amendments made statutory remedies exclusive for covered employment discrimination claims and abolished related Burk public policy tort claims, as Bennett v. Windstream Communications, Inc. explains.
Section 1101(b) calls for liberal construction of the Act to further its purposes, preserving common-law wrongful-discharge claims based on racial discrimination or retaliation.
Tate v. Browning-Ferris, Inc. · filed 1992-05-22(b)
Interpreting the Act liberally, as we must, in furtherance of its general purposes, we are not persuaded that common-law rights stand abrogated for workers who claim to have been discharged under the circumstances alleged by the plaintiff in this case.Read the full opinion on CourtListener →
Law changed since The 2011 OADA amendments removed § 1101(A)’s express reference to federal civil rights law, as Hauck v. Putnam City Independent School District I001 explains; this opinion interpreted the former purpose clause.
Section 1101 states the purpose of Oklahoma’s anti-discrimination scheme by reference to specified federal discrimination laws; it does not make § 1983 part of that scheme.
Glenn v. State ex rel. Department of Corrections · filed 1997-04-01
However, we find those sections inapplicable. As part of Oklahoma’s statutory anti-discrimination scheme, section § 1101 clearly states its purpose, i.e., to “provide for execution within the state of the policies embodied” in the federal Civil Rights Act of 1964, the federal Age Discrimination in Employment Act of 1967, and the federal Rehabilitation Act of 1973. There is no mention of § 1983.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 1101 incorporates Title VII’s policies but distinguishes those policies from the Act’s remedies.
Collier v. Insignia Financial Group · filed 1999-05-25(A)
Construction of this language leads inescapably to the conclusion that while the Legislature meant to incorporate the policies of Title VII (among other federal acts), it intended that the Act’s primary remedial scheme be that afforded by the Fair Housing Law.Read the full opinion on CourtListener →
Law changed since The 2011 OADA amendments made statutory remedies exclusive for covered employment discrimination claims and abolished related Burk public policy tort claims, as Bennett v. Windstream Communications, Inc. explains.
Section 1101's purpose of prohibiting racial discrimination in employment supplies public policy for a Burk tort claim regardless of employer size.
Smith v. PIONEER MASONRY, INC. · filed 2009-11-10
In conclusion, we hold that one of the primary purposes of Oklahoma's Anti-Discrimination Act is to prohibit racial discrimination in employment and to make such discrimination a legal wrong. This purpose constitutes a general declaration of public policy on this subject. To vindicate violations of this policy, the Act provides statutory remedies in cases where employers have more than fifteen employees, while the common law provides a Burk tort to all victims of racial discrimination regardless of the number of employees.Read the full opinion on CourtListener →
Exclusive remedies
Section 1101(A) makes OADA remedies exclusive for employment discrimination claims and abolishes related Oklahoma public policy tort claims.
Bennett v. Windstream Communications, Inc. · filed 2014-06-27(A)
To the extent Bennett’s claim is based on violation of Oklahoma public policy— i.e., a Burk tort claim — such claims were abolished effective November 1, 2011, when the OADA was amended to provide for ... Okla. Stat. tit. 25, § 1101(A) (emphasis added).Read the full opinion on CourtListener →
Section 1101(A) makes the OADA’s remedies exclusive for employment sex discrimination claims and precludes a tortious interference claim based on the same alleged discrimination.
Jones v. Needham · filed 2017-05-12(A)
The OADA “provides for exclusive remedies within the state of the policies for individuals alleging discrimination in employment on the basis of ... sex.” Okla. Stat. tit. 25, § 1101(A). ... The district court concluded that since Mr. Jones’s tortious interference claim was based on the same set of facts as his sex discrimination claim it fell within the OADA’s limitation of common law remedies. We agree.Read the full opinion on CourtListener →
Section 1101(A) makes the Oklahoma Anti-Discrimination Act an exclusive remedy for employment-related discrimination.
Watts v. Oklahoma Department of Mental Health and Substance Abuse Services · filed 2020-05-20(A)
By statutory amendments in 2011, the Oklahoma Legislature removed any doubt that OADA provides an exclusive remedy for employment-related discrimination. See Okla. Stat. tit. 25, §§ 1101(A), 1350(A).Read the full opinion on CourtListener →
Section 1101(A) makes the OADA's remedies exclusive for employment discrimination based on the listed protected characteristics.
MacDONALD v. CORPORATE INTEGRIS HEALTH · filed 2014-02-25(A)
The Legislature has declared that the OADA "provides the exclusive remedies within this state . . . for individuals alleging discrimination in employment on the basis of race, color, national origin, sex, religion, creed, age, disability or genetic information." 25 O.S.2011, § 1101(A) (emphasis added).Read the full opinion on CourtListener →
Section 1101 makes the OADA’s remedies exclusive for covered employment discrimination claims and preempts tortious interference claims based on the same conduct when their legal theories are not sufficiently distinct.
Patterson v. Rural Water District 2 Cotton County · filed 2020-02-07
The OADA “provides for exclusive remedies within the state of the policies for individuals alleging discrimination in employment on the basis of . . . age [or] disability.” 25 O.S. § 1101. ... In accordance with the guidance provided by the Tenth Circuit, Plaintiffs sixth and seventh causes of action for tortious interference are therefore preempted by the OADA.Read the full opinion on CourtListener →
Section 1101 preempts tortious-interference claims based on age or disability discrimination unless the tort rests on a sufficiently distinct legal theory.
Coleson v. Feed The Children Inc · filed 2022-07-08
Consequently, to the extent Plaintiff relies on his claims of age and disability discrimination as the factual basis for his intentional interference with contract and prospective economic advantage causes of action, they are preempted and barred by the OADA.Read the full opinion on CourtListener →
Section 1101 makes the Oklahoma Anti-Discrimination Act the exclusive remedy for employment discrimination and preempts common law claims arising from the same conduct.
BAUGHMAN v. WORLD ACCEPTANCE CORPORATION · filed 2025-09-16
Here, the plain language of Sections 1101 and 1350 reflect the Legislature's intent for the OADA to comprehensively govern employment discrimination under state law and to preempt any common law claims arising from the same conduct.Read the full opinion on CourtListener →
60 more cases cited this section only in passing
These cases mention the section without interpreting it (a string cite, a footnote, background). Listed so you can see the full citation record, not just the annotated rulings.
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