Jones v. Needham, 856 F.3d 1284 (10th Cir. May 12, 2017)

In this discrimination case, the employer argued that employee failed to exhaust administrative remedies because the complaint contained a quid pro quo harassment claim that was absent from the charge of discrimination.  The Tenth Circuit held that the discrimination charge satisfied the exhaustion requirement where it placed the employer on notice of a claim based on sex-based remarks and discrimination, even though it did not specifically mention a quid pro quo harassment.