Frequently Asked Questions

Basic Information

1. Why is there a notice?

The Notice is to inform you of a proposed settlement class in the action called Gloria Richards and Depreesha Smith v. Oregon Health and Science University, No. 21CV47583 (Mult. Cty. Cir. Ct.). You are a member of the proposed class if: 1) You work or worked for OHSU; 2) You are or were a member of AFSCME or ONA; 3) You identify as Black or as a person of color; and 4) You received formal discipline measures short of discharge between September 10, 2019, and December 31, 2021.

Because you may be a member of the proposed Class, you have the right to know about a proposed Settlement of class action lawsuit, and about your options, before the Court decides whether to approve the Settlement.

2. What is this lawsuit about?

The Court in charge of this case is the Multnomah County Circuit Court in Multnomah County, Portland, Oregon (the “Court”). The case is called Gloria Richards and Depreesha Smith v. Oregon Health and Science University, No. 21CV47583 (Mult. Cty. Cir. Ct.). The case is assigned to the Honorable Christopher A. Ramras.

The individual who sued on behalf of the class is called the Class Representative. Here, that person is Depreesha Smith. She sued her employer, OHSU.

The lawsuit alleges that OHSU violated certain laws by its discipline policies and practices that resulted in discriminatory discipline of AFSCME and ONA employees who identify as Black or as people of color. OHSU denies any wrongdoing and has asserted various defenses that it believes are meritorious. The Court has not made any rulings on the merits of the parties’ claims or defenses.

3. Why is this a class action?

In a class action, one or more people called Class Representatives (in this case, Depreesha Smith), sue on behalf of other people who have similar claims, all of whom are known as “the Class” or “class members.” Bringing a case as a class action allows a court to adjudicate many similar claims that might be economically too small to bring in individual actions. One court resolves the issues for all class members, except for those who decide to exclude themselves from the class.

4. Why is there a settlement?

OHSU denies that it did anything wrong. All parties have agreed to a settlement of the claims in this case, which will allow the parties to avoid the risk and cost of further litigation. The Court has not decided the case in favor of the Class or Defendants. The Class Representative and her attorneys think the Settlement is best for the Class.

Who Is Included In The Settlement?

5. How do I know if I am part of the Settlement?

The Class includes all persons who1) Work or worked for OHSU; 2) Are or were a member of AFSCME or ONA; 3) Identify as Black or as a person of color; and 4) Received formal discipline measures short of discharge between September 10, 2019, and December 31, 2021.

6. What if I am still not sure if I am included in the Settlement?

If you are not sure whether you are a class member, or have any other questions about the Settlement, you should email info@OHSUClassSettlement.com or call the Claims Administrator toll-free at (888) 369-3780.

Settlement Terms

7. What types of relief does the Settlement provide?

The Settlement provides monetary relief to all class members. All Class Members will be entitled to a payment of approximately $4,000.00.

8. What is the Settlement Fund?

OHSU has agreed to pay $750,000.00.00 as part of the Settlement. That amount will be used to pay all settlement expenses, including the costs of Class Notice and administration, attorneys’ fees and costs, and a service award for the Class Representative.

9. What can I get from the Settlement?

All class members will receive a payment of approximately $4,000.00. The amount may vary based upon the exact number of class members, the cost of class administration, and the amount that the Court awards in attorney fees and costs.

10. How do I get a payment?

If you received a mailed or email Notice, you are entitled to a payment and do not need to file a claim.

If you believe you should have received a Notice or believe you are a Settlement Class Member, please contact the Claims Administrator at info@OHSUClassSettlement.com and provide your full name, current mailing address, phone number and/or email address, and any information that may help us locate you in the Defendant’s records (e.g., former name, work location, approximate employment dates, employee ID if known). We will review your information and, if appropriate, request verification from the Parties. If you are confirmed as eligible, we will update our records and provide next steps.

11. What am I giving up to get a Cash Award?

If you are a Class Member and do not seek to exclude yourself from the Settlement, you cannot sue, continue to sue, or be a part of any other lawsuit against OHSU about the claims released in this Settlement. It also means that all decisions by the Court in this case will bind you.

The Released Claims are defined in the Settlement Agreement. The Released Claims relate to the claims filed in the lawsuit, which are set forth in the Second Amended Complaint. Both the Settlement Agreement and the Second Amended Complaint are available, along with other case-related documents, on the Important Documents page.

Participating in the Settlement

12. How do I update my contact information?

If you received a mail or email Notice and would like to update your contact information, you must contact the Claims Administrator at:

Gloria Richards and Depreesha Smith v. Oregon Health and Science University
c/o Claims Administrator
P.O. Box 26170
Santa Ana, CA 92799
Telephone: (888) 369-3780
Email: info@OHSUClassSettlement.com

13. When will I get my Cash Award?

Cash Award payments will be made after the Court grants “Final Approval” to the Settlement, and after any appeals are resolved. If the Court approves the Settlement, there may be appeals. It is always uncertain when these appeals will be resolved and resolving them can take time.

14. How will the amount of the Cash Award be determined?

The amount of the Cash Award will be determined by subtracting the amounts of attorney fees and costs, class administration costs, and class representative service payment—all of which must be approved by the Court—from the settlement amount. The remaining amount will be divided equally between the class members. Based on review of the records of OHSU, Class Counsel believes that there are 134 class members. Class Counsel estimates that each class member will receive at least $4,000.00.

Excluding Yourself From The Settlement

15. How do I get out of the Settlement?

If you do not want to be bound by the Settlement, you must request to be excluded from the Settlement. If you request to be excluded, you will retain any individual rights you have against OHSU and will not be deemed to have individually “released” any of the Defendants from any of the Released Claims. However, you will not be eligible to receive compensation under the Settlement, as described above. You also may not object to the Settlement if you request to be excluded.

To exclude yourself (or “opt out”) from the Settlement, you must either complete and email the Opt-Out Form, or print, complete, and mail the Opt-Out Form to the Class Administrator at the following address:

Gloria Richards and Depreesha Smith v. Oregon Health and Science University
c/o Claims Administrator
P.O. Box 26170
Santa Ana, CA 92799

You may download the Opt-Out Form here, complete and email to the Claims Administrator at info@OHSUClassSettlement.com.

To be excluded from the Settlement, you must email the Opt-Out Form to info@OHSUClassSettlement.com before May 12, 2026, or print and mail the Opt-Out Form to the Class Administrator, postmarked on or before May 12, 2026.

16. If I don’t exclude myself, can I sue Defendants for the same thing later?

No. Unless you exclude yourself, you give up any right to sue OHSU for the claims that this Settlement resolves. If you have a pending lawsuit, speak to your lawyer in that lawsuit to determine whether you must exclude yourself from this Settlement to continue your own lawsuit. If you properly exclude yourself from the Settlement, you will not be bound by any orders or judgments entered in this case relating to this Settlement.

17. If I exclude myself, can I still get a Settlement payment?

No. You will not get any money from the Settlement if you exclude yourself. If you exclude yourself from the Settlement, you will not receive a Cash Award.

Objecting To The Settlement

18. How do I tell the Court if I do not like the Settlement?

If you are a class member, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. This includes Class Counsel’s motion for an award of attorneys’ fees and costs and expenses, and/or the requested service award payment to the Class Representative. Please note that the Court cannot order a larger Settlement or award you more based on your individual circumstances; the Court can only approve or deny the Settlement as it is presented.

If you wish to object, your objection must contain the following:

1. The name of this action Gloria Richards and Depreesha Smith v. Oregon Health and Science University, 21CV47583 (Mult. Cty. Cir. Ct.)), and a statement that the document is an objection;

2. Your full name, address, and telephone number or, if objecting through counsel, your lawyer’s name, address, and telephone number;

3. A clear and concise statement of your objection, as well as any facts and law supporting the objection; and

4. You and/or your attorney’s signature.

To be considered by the Court, your objection must be either filed with the Court or mailed to the Class Administrator, postmarked no later than May 12, 2026. The objection may be mailed to the Class Administrator at the following address:

Gloria Richards and Depreesha Smith v. Oregon Health and Science University
c/o Claims Administrator
P.O. Box 26170
Santa Ana, CA 92799

If you do not comply with these procedures and the deadline for objections, you may waive your opportunity to have your objection considered at the Final Approval Hearing or otherwise to contest the approval of the Settlement or to appeal from any orders or judgments entered by the Court in connection with the proposed Settlement. You will still be eligible to receive settlement benefits if the Settlement becomes final, even if you object to the Settlement.

Objecting class members may appear at the Final Approval Hearing but are not required to do so. Class members who wish to appear are requested, but not required, to mail to the Class Administrator or file with the Court a Notice of Intent to Appear.

Instructions and requirements for objecting are set forth in the Court’s Preliminary Approval Order, which is available here.

19. What is the difference between objecting and excluding myself?

Objecting is simply telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from the settlement. Excluding yourself from the Settlement means telling the Court that you do not want to be part of the Settlement at all. If you exclude yourself from the Settlement, you have no basis to object to the Settlement because it no longer affects you.

The Lawyers Representing You

20. Do I have a lawyer in this case?

Yes. The Court has appointed the lawyers at Sugerman Dahab as the lawyers for the Class (“Class Counsel”). The lawyers representing you will be paid, only with the Court’s approval, from the settlement fund, as explained below. If you want to be represented by your own lawyer, you may hire one at your own expense.

21. How will the lawyers be paid?

Class Counsel spent considerable time and effort prosecuting this matter on a purely contingent fee basis and advanced the expenses of the litigation, with the expectation that they would receive a fee, and have expenses reimbursed, only if there was a benefit created for the Class. Class Counsel will file a motion on or before May 29, 2026, seeking an award of fees of no more than 25 percent of the settlement fund, and reimbursement of case expenses to date, plus any expenses incurred after preliminary approval. Class Counsel will also ask the Court, on behalf of the Class Representative, for a service award for Depreesha Smith in the amount of $7,500.00.

After Class Counsel’s motion for attorneys’ fees, expenses, and service award is filed, it will be posted here and you will have an opportunity to review and comment on the motion by filing an objection. The Court will then determine the amount of fees, expenses, and service awards to be paid from the settlement fund.

Notice And Administration Expenses

22. How will notice and administration expenses be paid?

Using the Claims Administrator’s estimates regarding the class size and likely claims rate, notice and administration expenses, to be paid from the settlement fund, are currently estimated to be $8,400.00.

Final Approval Hearing

23. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Approval Hearing (sometimes called a “Fairness Hearing”) on June 23, 2026, at 1:30 p.m., at the Multnomah County Circuit Court, 1200 SW First Avenue, Portland, Oregon 97204. At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and may also consider how much to award to Class Counsel and the Class Representative. If there are objections, the Court will consider them at that time. After the hearing, the Court will decide whether to approve the Settlement.

24. Do I have to come to the hearing?

No. Class Counsel will answer any questions that the Court may have, but you may come at your own expense. If you submit an objection, you do not have to come to the Court to talk about it. If you timely mail your written objection to the Claims Administrator (see Question 18 above), Class Counsel will submit it to the Court on your behalf for consideration. You may also pay your own lawyer to attend, but it is not necessary.

25. May I speak at the hearing?

Yes. You may appear and speak at the Final Approval Hearing. Although it is not required, if you intend to appear and speak, you are requested to mail notice of your intent to appear no later than May 12, 2026, to the same address identified above for objections. Persons who opt out, however, may not appear and be heard.

What Happens If You Do Nothing?

26. What happens if I do nothing at all?

If you do nothing, you will be a member of the Class and will be bound by the release of claims in this Settlement. If you received a Notice by mail or email, you will be issued a settlement payment for the Cash Award. Unless you exclude yourself, if the Settlement is approved, you will not be able to start a lawsuit or be part of any other lawsuit against OHSU relating to the claims alleged in this case.

Where Can I Get More Information?

27. How can I get more information?

This website and the Notice summarize the proposed Settlement. More details are in the Settlement Agreement and in other case-related documents, which are available on the Important Documents page. If you have additional questions, contact the Claims Administrator:

Gloria Richards and Depreesha Smith v. Oregon Health and Science University
c/o Claims Administrator
P.O. Box 26170
Santa Ana, CA 92799
Telephone: (888) 369-3780
Email: info@OHSUClassSettlement.com

Updates will be posted as information about the Settlement process becomes available.

You may also contact Class Counsel with any questions:

Please do not telephone or address any questions about the case or Settlement to the Clerk of the Court or to the Judge. They are not permitted to answer your questions. The Court expresses no view as to the merits of any claims or defenses asserted by any party to the Action.