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Declaration Summaries

 

Barbara Steele:

Barbara Steele worked her way up to store manager after working in several stores around the country, including in Missouri, Texas, New Mexico, Idaho, and Washington.  She currently lives in Arizona.  Ms. Steele had been an assistant manager for six years with no disciplinary action and only positive evaluations.  She is personally aware of several men who got promoted much more quickly than she did to store manager positions.  In her four years as a store manager, Ms. Steele enhanced the performance of both stores in which she worked but, in 1999, she was quickly demoted to assistant manager for back-dating one employee's evaluation.  Ms. Steele then spent the next three years trying to get re-promoted to store manager.  She never got promoted past grocery co-manager and men received almost all of the more than 24 positions for which she applied.  While Ms. Steele had over four years’ store manager experience, many of these men had no experience as a store manager.  The male district manager who demoted her was later fired for violation of the fraternization policy and then, within 90 days, was rehired into one of the store manager positions for which she applied. 

 

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Sandra Stevenson:

Sandra Stevenson worked at the Gurnee, Illinois Sam's Club from November 1996 to June 2000.  Throughout her employment, Ms. Stevenson requested promotion to management positions in the hopes that she could move up and, ultimately, retire with the company.  Her dreams were shattered, however, after she was repeatedly denied the staff she needed to perform her responsibilities as an overnight supervisor while she watched as male managers supported and promoted less experienced male employees.  Eventually, Ms. Stevenson requested to be transferred to the day shift and accepted the position of team leader for produce and floral with the expectation that she would be promoted to produce manager.  Again, she found that management would not support her with adequate staffing.  At one point, Ms. Stevenson was forced to work in the Produce Department during a busy Easter weekend without any assistance because the store manager fired her only staff person and had failed to provide her with a substitute.  This was particularly upsetting to her because she also was forced to miss the wake of a family member because of her huge workload.  She also watched as male partners were groomed for management while she was left unsupported.  Ms. Stevenson resigned from Sam's Club because she had had it with the repeated denials of support and promotion to management despite her qualifications and desire for promotion.  Ms. Stevenson currently lives in Lake Villa, Illinois.

 

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Kim McLamb:

            Mrs. McLamb worked for Wal-Mart from 1991 to 2001 as an assistant manager throughout Virginia.  She was an excellent employee who continuously received “exceeds expectations” ratings on her evaluations.  From the beginning of her employment, Mrs. McLamb regularly expressed an interest in promotion to several store managers and district managers.  At one point, she was required to commit, in writing, to working overnights for a full two years.  Male assistant managers were only required to rotate through the overnight position on a six-month basis.  Mrs. McLamb was also passed over for management positions in favor of less experienced and less qualified men.  When Mrs. McLamb discovered that male employees made more than female employees working the same jobs, she complained to three different assistant managers.  Each told her it was because the men “had families to support.”  At one point, in 2001, when Mrs. McLamb and a number of other female assistant managers were working around the clock to prepare for inventory, the male store manager and male assistant managers spent their time training for a triathlon.  They would bring their bikes into the store and often left work early to train.  Unlike the female assistant managers, the males would rarely work on weekends. 

 

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Ramona Scott:

            Ramona Scott worked for Wal-Mart in Florida from 1990 to 1998.  While working in Pinellas Park, Florida, Ms. Scott was a personnel manager who had access to payroll records.  She noticed that men generally made more than women who had as much or more seniority.  When she asked the male store manager about the pay discrepancy, he told her, “Men are here to make a career and women aren’t.  Retail is for housewives who just need to earn extra money.”  When Ms. Scott later inquired about a raise that a male employee had received, she was told by a male assistant manager, “He has a family to support.”  When she pointed out that she was a single mother, the assistant manager ignored her and walked away.  When Ms. Scott expressed an interest in promotion into the Management Training Program, her district manager merely told her there were no openings but did not give her guidance or information about how to get into the program.  When a new male store manager took over her store, he laughed at Ms. Scott’s pay rate and told her that the male personnel manager at his former store made “a lot more” than she did.  This same store manager dismissed her renewed request to enter the Management Training Program.  He then told her that if she wanted to get along with him, she would have to behave like his wife and frequently asked her to get coffee for him and other male managers. 

 

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Claudia Renati:

            Claudia Renati began working at a Sam's Club in Roseville, California in 1993 as a marketing membership team leader.  Early on, Ms. Renati became responsible for running the marketing programs in the region after the regional sales manager left.  After two years of performing the tasks of both positions without the additional pay or the correct job title, she asked the director of operations to promote her into the position.  He refused because she had not gone through the Management Training Program.  Over the next couple of years, the position of marketing manager was filled by several male next-door neighbors of the director of operations.  None had gone through management training and none had experience in marketing.  Ms. Renati was responsible for training these less qualified and less experienced men who were hired to be her supervisors.  Over the next several years, Ms. Renati trained approximately 20 male managers, many of whom never went through the Management Training Program nor were required to relocate.  Ms. Renati continued to be passed over for promotions for positions that were consistently filled by males with no prior management experience and less seniority.  At one point, the director of operations told Ms. Renati that before she could become a manager, she would be required to stack 50-pound bags of dog food as a floor team leader.  When Ms. Renati indicated that she could not repeatedly lift 50 pounds, he told her he could not help her advance. Ms. Renati is aware of several male employees who never had to become floor team leader, nor were required to stack 50-pound bags of dog food in order to enter the Management Training Program.

 

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Christine Kwapnoski:

Christine Kwapnoski has worked for Sam's Club since 1986 in a variety of positions with ever increasing responsibilities.  Her evaluations have been outstanding, and she received a number of merit raises over the years.  Nevertheless, despite frequent requests for promotion, she was not allowed to join the ranks of management.  The director of operations claimed she had "people issues," in that she was too direct and outspoken.  Finally, two weeks after this suit was filed, Chris was promoted to an area manager.  Because this is a salaried position with no overtime pay, her hourly rate actually decreased.  While in this position, she was told by the General Manager of the Club to "doll up" and "blow the cobwebs off her makeup."  She stayed an area manager for 1½ years until, at his deposition, Executive Vice President of Sam's Club, Gregg Spragg learned she had not been promoted to assistant manager.  Ms. Kwapnoski entered Management Training in March 2003.

 

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Nancy Hom:

Nancy Hom was an assistant manager for Sam's Club for 10 years.  She is very familiar with all the personnel procedures and witnessed men being paid more than women. She is aware of larger and more frequent raises being given to men than women.  She observed the double standards and gender stereotypes that prevented women from being promoted.  For example, she was told by the director of operations that Christine Kwapnoski could not be promoted because of undefined 'people issues', and watched as he ordered the male general manager to take anger management classes but did not find him to be inappropriate for management.

 

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Betty Dukes:

Betty Dukes has been unable to receive promotions due in large part to the failure to fairly post job openings.  Ms. Dukes has worked for Wal-Mart in the San Francisco Bay Area for nine years and earns less than $9.00 an hour.  She is aware of men who have been hired more recently for the same position who are paid more than she is.

 

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Gretchen Adams:

Gretchen Adams was an hourly employee, an assistant manager, and a co-manager.  Twice, she learned that male trainees, whom she was training, were paid more than she was paid.  She then learned that two male co-managers at the same store with less tenure were paid more than she was paid.  She witnessed demeaning treatment of female employees, including when a district manager called her a “worthless broad."  As co-manager, she received 'talking points' from Home Office for her to use in answering questions about this lawsuit.  She then learned her experience of gender discrimination was not isolated.  She quit Wal-Mart a few months later.

 

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Stephanie Odle:

Stephanie Odle worked for Sam’s Club stores in California, Nevada and Texas for nearly nine years.  For approximately six years of her Sam’s Club career, Ms. Odle held the position of assistant manager.  During her employment at Sam’s Club, Ms. Odle encountered discrimination in various forms: denial of her requests for promotion, inappropriate gender-based comments made by her supervisors, gender-based pay inequities, gender-based discriminatory discipline, and retaliation for reporting such discrimination.  In 1999, Ms. Odle’s application for a co-manager position at a Tulsa, Oklahoma, Sam’s Club store was sabotaged by her general manager, who unfairly disciplined her during her candidacy for the vacant position, thereby dooming her application.  In October, 1999, the general manager of Ms. Odle’s store informed her that her employment was terminated based upon her supposed “violation of company policy.”  Ms. Odle’s termination came within days after her complaints about her exclusion from an opportunity to take a test used to demonstrate one’s capability to act as a general manger, as well as her reporting her general manager’s failure to comply with company policies.  Subsequent to her termination, Ms. Odle also discovered that prior to the discipline and termination, Sam’s Club had authorized a male manager from Phoenix, Arizona to replace her, leading her to believe that her termination was “pre-arranged” to make room for the male manager.  Ms. Odle currently lives in Tulsa, Oklahoma.

 

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Dedra Farmer

Dedra Farmer is a Lawrence, Kansas resident and 13-year veteran Wal-Mart employee.  Ms. Farmer, who received numerous commendations and consistently laudable performance evaluations, worked in Kansas Wal-Mart stores in positions of associate, various department manager positions and Tire Lube Express (“TLE”) Manager.  When Wal-Mart finally granted Ms. Farmer’s promotion to TLE Manager, she was placed her in a Sam’s Club that was notorious for being a low-volume, old, small and understaffed store out of which it was extremely difficult to be promoted.  Ms. Farmer’s male contemporaries in the TLE Management Training Program were placed in higher volume stores which provided them with greater opportunities to increase their salaries because a TLE Manager’s bonus is based on the profit of his or her department, which is always higher in stores with higher overall volume.  Ms. Farmer expressed her displeasure at being assigned to the low volume, poor performing store to her supervisors many times and repeatedly requested transfers to higher volume stores to no avail.  In addition to making numerous complaints regarding gender discrimination to her direct supervisors, Ms. Farmer made two complaints regarding equal pay disparity issues to Wal-Mart CEO Lee Scott in 2000 and 2001.  Wal-Mart responded by assuring Ms. Farmer that it would create spreadsheets on gender gap pay issues, but Wal-Mart never apprized Ms. Farmer whether it created the spreadsheets and analyzed them, what the results showed, or even if the spreadsheets were ever created.  Ms. Farmer was terminated on December 31, 2002 after she complained to her supervisors and Wal-Mart CEO Lee Scott about sexual discrimination.  This was also after she had agreed to participate in the Dukes v. Wal-Mart case (including having her deposition taken by Defendant Wal-Mart in August, 2002) and after she had assisted a female Wal-Mart associate with her complaints of sexual harassment. 

 

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Micki Earwood

Micki Earwood is a Springfield, Ohio resident worked for Wal-Mart for 10 years.  Ms. Earwood held jobs as an associate, department manager, support manager and personnel manager at three separate Ohio Wal-Mart stores.  Despite consistently receiving highly rated performance evaluations, Wal-Mart denied Ms. Earwood’s repeated requests to be placed into the Management Training Program, thus denying her the opportunity to obtain a salaried Wal-Mart manager position.  During her tenure as a personnel manager, Ms. Earwood had access to employee payroll information and thus had the unique opportunity to witness first-hand Wal-Mart’s discrimination against women with regard to compensation.  Ms. Earwood reported these gender-based pay discrepancies to her superiors.  Instead of addressing to Ms. Earwood’s complaints of discrimination, Wal-Mart wrongfully terminated her in September, 2000, based upon her whistle-blowing activities.           

 

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Laverne Jones

Laverne Jones, currently resides in Pontotoc, Mississippi and began working for Wal-Mart in 1977 with high hopes of a long and successful career with the emerging company.  Within six months, Wal-Mart promoted her to a Department Manager position, an hourly supervisory job that is just a step away from the higher–paying realm of salaried management.  For the next 25 years Ms. Jones tried to make the jump into the Management Training Program, which would have opened the door for her to salaried positions.  Despite making multiple requests to be promoted into management and a quarter-century of exemplary work history, Ms. Jones has remained an hourly associate making less than $29,000 per year.  A fellow male employee, on the other hand, who also started at the Pontotoc, Mississippi store in 1977, was placed into the Management Training Program and is now a District Manager earning a base salary that significantly dwarfs Ms. Jones’ meager wages.

 

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Karla Rojas

Karla Rojas, who received a BSBA degree in Marketing from the University of Arkansas (Fayetteville) and lives in Dallas, Texas, began working for Wal-Mart in 1983.  Ms. Rojas’ Wal-Mart career spanned nearly 17 years.  Recognizing her management potential, Wal-Mart hired Ms. Rojas directly into the Management Training Program after she graduated from college, which program grooms employees to become salaried Wal-Mart managers.  Ms. Rojas worked as a Wal-Mart manager in positions of assistant manager, operations assistant manager, co-manager, acting store manager and store manager.  Ms. Rojas also worked at the Wal-Mart Home Office in Bentonville, Arkansas as a fashion distributor and associate buyer.  Ms. Rojas repeatedly made it known to her supervisors that she wanted to be a store manager of a large Wal-Mart store.  For years, her supervisors instructed her to work in certain positions in order to ensure a promotion to store manager.  Then, after Ms. Rojas would followed their advice and obtained the position in question, her supervisors would inform her that the promotion rules had changed and that she should pursue an alternative promotion path.  Meanwhile, males with experience comparable to or less than that of Ms. Rojas were rapidly promoted into store manager positions.  When Ms. Rojas finally achieved store manager status after 12 years of dedicated service to the company, Wal-Mart discriminatorily assigned her to a previously mis-managed and dysfunctional store, ensuring that she would not advance further. 

 

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Melissa Howard

Melissa Howard worked at Wal-Mart from 1992 to 2000.  Despite excellent evaluations and her stores making a profit, Ms. Howard felt she had to leave Wal-Mart due to the abuse and mistreatment she received based on her gender.  In 1998, when Ms. Howard was a store manager in Decatur, Indiana, she was required to attend district meetings at a Hooter's Restaurant.  On one occasion, Ms. Howard and two male members of management were driving to a management meeting in Bentonville, Arkansas when the male managers insisted on  stopping at a strip club.  As she did not feel safe sitting by herself in the dark parking lot of the strip club, Ms. Howard felt she had no choice but to accompany the male managers into the club.  While in the club, Ms. Howard was approached by a stripper and the male district manager proposed they all have a "threesome out back."  On the return trip to Indiana, two more stops were made at strip clubs where Ms. Howard sat in the back of the club, but was able to observe several males up front paying for lap dances.  On the return trip, the male managers insisted on stopping at two more strip clubs.  Ms. Howard and another female managers sat in the back while observing several of the male managers pay for lap dances.  Although Ms. Howard continued to receive "exceeds expectations" ratings on her performance evaluations, she was continuously criticized and berated for her job performance during her time at Wal-Mart.  She was also paid at a lower rate than other male store management.  By 2000, she was so fed up and felt so undermined in her management career, that and she felt she had no choice but to leave Wal-Mart.

 

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Deborah “Dee” Gunter:

Dee Gunter worked at three different Wal-Mart stores in Southern California from April 1996 through August 1999.  She had extensive retail and management experience prior to joining the company.  Despite her qualifications, Wal-Mart repeatedly denied Ms. Gunter promotion opportunities.  On three separate occasions, Ms. Gunter applied for, but was denied, the position of support manager in Wal-Mart’s Tire Lube Express Specialty Division in favor of men who had less time with the company and who were often less qualified than she.  Ms. Gunter was required to train each of these men immediately prior to their promotions.  During the two years she worked as an overnight stocker, Ms. Gunter was paid approximately $2.00 an hour less than some of her male co-workers.  She was only earning  $7.50 an hour when she left the company.

 

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Jennifer Furtado:

Jennifer Furtado worked for Wal-Mart in New Hampshire and New Mexico from January 1992 through March 1999.  She joined the company right out of high school as a cashier and worked her way up to department manager, support manager and then into the Management Training Program.  Ms. Furtado received four awards for her outstanding job performance and numerous evaluations in which she was rated as “exceeds expectations.”  Despite earning her Bachelor of Arts degree and taking graduate business courses while working mostly full-time, Ms. Furtado was never promoted to an assistant manager position.

 

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Susan McFarland Ramirez:

Sue Ramirez worked in over fifty Wal-Mart stores in Oklahoma, Missouri and Texas from August 1989 through September 2001.  She worked her way up from a customer service manager to a district assistant, a district manager in the Jewelry and Shoes Specialty Division, an assistant manager and a co-manager.  She was never disciplined and had excellent performance evaluations. She was never promoted to a store manager position.

 

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Gina Espinoza-Price:

Gina Espinoza-Price was employed by Wal-Mart from November 1990 through April 1997.  She worked her way up from an hourly associate to International Liaison for the Photo Division.  Ms. Espinoza-Price was an extremely valuable asset to Wal-Mart:  she wrote many of Wal-Mart’s Specialty Division Distribution Center procedures and she helped open Photo departments in new stores in Canada, Mexico, and the United States.  Despite her qualifications, Ms. Espinoza-Price was repeatedly overlooked for promotion to regional photo manager in favor of male photo district managers who had less experience than she or whom she had  trained. She also was subjected to sexist and racist comments by a male regional photo manager, including being called “the little Mexican princess.”   

 

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Vicki Thornton:

In 1998, Vicki Thornton quit her job as a store manager at another retail store and took a 30% pay cut to work for a Wal-Mart in Racine, Wisconsin.  She believed it would be a good career move because she was promised that, within six months, she would be promoted into the management ranks and could easily work her way up in the company.  After three years, despite her hard work and excellent evaluations, Ms. Thornton had still not been promoted to the Management Training Program.  During this time, she constantly asked to be considered for promotion to the Management Training Program but she was always told there were no openings.  At the same time, she watched as male employees with less experience were admitted to the training program.  In addition, Ms. Thornton was also sexually harassed by two male department managers during her Wal-Mart tenure.  She complained many times to her store manager and assistant manager who told her to just “grin and bear it.”  Ms. Thornton left Wal-Mart in 2001.

 

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Dawn White:

Dawn White has worked for Wal-Mart for about 7 years.  She currently works as department manager of Hardware in a Wal-Mart Supercenter in Valdosta, Georgia.  On several occasions, she has been asked to train less experienced male employees who were being groomed for management.  Some of these men were paid significantly more than she was even though they had less experience.  The store manager focused his attention on male department managers, training them and preparing them for promotions.  He virtually ignored Ms. White and despite her frequent requests, he refused to assist her in obtaining and applying for promotions.  Ms. White remains with Wal-Mart but is very disillusioned with her Wal-Mart career.  She and her family are planning to move out of state and is looking forward to finding a new employer who will appreciate her abilities and ambitions.

 

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Trudy Crom:

Trudy Crom worked for Wal-Mart Stores in Colorado from 1990 to 2002 when she went out on disability leave.  She continually expressed interest in entering the Management Training Program to her store manager and assistant managers but to no avail.  Eventually, she wrote a letter to the Wal-Mart CEO describing her frustration with promotional opportunities but she received no response.  Shortly thereafter, she began experiencing harsh and constant criticism from her store and assistant manager—something she had not experienced before she wrote the letter.  She was not promoted into the Management Training Program until 1999—nine years after she had first expressed an interest and only after she agreed to relocate.  In the mean time, she witnessed several less experienced men get promoted more quickly into management and who were not required to relocate.  Even after her promotion to management, she was only an assistant manager for one year before she received an unfair coaching and demotion.  When she tried to use the Open Door Policy again, she never received any response.  She then wrote another letter to the Wal-Mart CEO expressing her concerns but, once again, she never heard back from anyone. 

 

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