Justia Oklahoma Supreme Court Opinion Summaries

Several agency heads in Oklahoma were appointed by the Governor to serve concurrently as Cabinet Secretaries. After these appointments, a state senator requested an opinion from the Attorney General regarding whether individuals could simultaneously hold multiple state offices. The Attorney General issued an opinion concluding that Cabinet Secretaries are not exempt from Oklahoma’s prohibition against holding dual office and, therefore, agency heads could not also serve as Cabinet Secretaries without violating state law.Governor Stitt then sought declaratory relief in the Oklahoma County District Court. After a hearing, the district court ruled in favor of the Attorney General, finding that Cabinet Secretaries are subject to the prohibition against holding dual office under Title 51, Section 6. The court reasoned that the expanded authority granted to Cabinet Secretaries, including the power to veto administrative rules, made them officers under Oklahoma law. As a result, the court concluded that agency heads serving as Cabinet Secretaries were unlawfully holding two offices. The district court also determined that Title 74, Section 10.3 did not create an express exception to the dual office prohibition. Governor Stitt appealed, and the Supreme Court of the State of Oklahoma retained the case.The Supreme Court of the State of Oklahoma held that Title 74, Section 10.3 expressly authorizes agency heads to serve concurrently as Cabinet Secretaries, notwithstanding the general prohibition against holding dual office in Title 51, Section 6. The Court found that the statutory language is clear and unambiguous, and that both statutes can be read together without conflict. The district court’s order was reversed, and the case was remanded with instructions to enter a declaratory judgment consistent with the Supreme Court’s opinion. View "STITT V. DRUMMOND" on Justia Law

Brightwater Capital obtained a judgment against Linzy Hill in 2012, which it renewed in 2017 but failed to renew again, causing the judgment to become dormant. After Hill’s death in 2022, his son Lenzy was appointed personal representative of the estate and published a notice to creditors, setting a deadline of September 27, 2022, for claims against the estate. Brightwater submitted its claim after this deadline, and the personal representative rejected it. Brightwater did not appeal the rejection but instead filed an ancillary petition in the probate case, seeking payment on the dormant judgment. The district court dismissed this petition without granting leave to amend.After the dismissal, Brightwater filed an amended ancillary petition, this time seeking payment from the personal representative’s bond. The district court treated this as a motion to reconsider, since Brightwater had not been granted leave to amend, and dismissed it with prejudice. Final appealable orders were entered, and Brightwater appealed only the order concerning the amended ancillary petition. The Court of Civil Appeals, Division IV, reversed, holding that Brightwater should have been allowed to file the amended petition.The Supreme Court of the State of Oklahoma reviewed the case de novo and held that, under Oklahoma law, once a case is dismissed, a party may not file an amended petition without leave of court. The court found that the district court properly dismissed Brightwater’s ancillary petition and correctly treated the amended filing as a motion to reconsider, since no leave to amend had been granted and the defect in the original petition could not be remedied. The Supreme Court vacated the Court of Civil Appeals’ opinion and affirmed the district court’s decision. View "In the Matter of the Estate of Hill v. Hill" on Justia Law

After the death of an individual who had lived in Johnston County, Oklahoma, for several years before his final illness and death in Oklahoma County, a dispute arose over the proper county for probate and which of two purported wills should be admitted. The decedent had executed a will in 2018, naming Cheryl Moore as personal representative and leaving his estate to his neighbors, the McClendons. In 2019, he executed another will and a trust, naming Moore as personal representative and leaving his assets to a trust benefiting the Oklahoma City Community Foundation, Inc. (OCCF). At his death, he owned property in Johnston County but had spent his last months in Oklahoma County for medical reasons.The District Court of Johnston County held an evidentiary hearing and determined that venue was proper in Johnston County, as the decedent had not abandoned his Johnston County residence. The court admitted the 2018 will to probate, finding the 2019 will was not executed with the statutory formalities required under Oklahoma law and could not be admitted as a lost or destroyed will. The court also found that Moore had renounced her right to serve as personal representative by not petitioning for probate within thirty days of the decedent’s death.The Supreme Court of the State of Oklahoma affirmed the district court’s rulings that venue was proper in Johnston County and that the 2018 will should be admitted to probate, as the 2019 will was not validly executed and did not revoke the earlier will. However, the Supreme Court reversed the finding that Moore had renounced her right to serve as personal representative, holding that mere passage of time without knowledge of her nomination was insufficient for renunciation. The case was remanded for further proceedings consistent with these holdings. View "ESTATE OF CUNNINGHAM v. MOORE" on Justia Law

The case concerns a dispute between purchasers of a used vehicle and the seller, a car dealership, over the enforcement of a vehicle service warranty contract. The purchasers alleged that after buying the vehicle and a service contract, they repeatedly sought repairs from the dealership, paid deductibles, were denied direct communication with the repair shop, and did not receive the necessary repairs. They claimed the dealership falsely represented that repairs had been completed. As a result, they filed suit for breach of contract, breach of warranty, and breach of the duty of good faith and fair dealing.The District Court for Tulsa County, presided over by Judge Damon Cantrell, reviewed the dealership’s motion for partial summary judgment. The dealership argued that Oklahoma’s Service Warranty Act, specifically Title 15, Section 141.24(B), barred tort claims for breach of the duty of good faith and fair dealing in connection with service warranty contracts. The purchasers contended that this statutory provision was an unconstitutional special law. Judge Cantrell denied the dealership’s motion, finding the statute unconstitutional.The Supreme Court of the State of Oklahoma reviewed the case on a writ of prohibition. The Court held that Title 15, Section 141.24(B) is not an unconstitutional special law because it applies uniformly to all service warranty contracts, including those issued by companies with significant assets, and does not single out a particular class for disparate treatment. The Court further held that the statute abrogates the prior judicial rule allowing tort claims for breach of the duty of good faith and fair dealing in this context. The Supreme Court granted the writ of prohibition, precluding enforcement of the lower court’s order, and remanded the case for further proceedings. View "AMERICA'S CAR MART v. CANTRELL" on Justia Law

Petitioners, resident taxpayers and registered voters in Oklahoma County, challenged the constitutionality of Senate Bill 632, which sought to create business court divisions within the district courts of Oklahoma County and Tulsa County. The Act provided for the appointment of business court judges by the Governor, with confirmation by the Senate and candidate lists supplied by the Speaker of the House. It also set forth qualifications, terms, salaries, and operational details for these judges and courts. Petitioners argued that the Act violated their constitutional rights, particularly the right to elect district judges, and would result in the unlawful expenditure of public funds.Prior to review by the Supreme Court of the State of Oklahoma, the Honorable Lonnie Paxton and Kyle Hilbert, legislative leaders named as respondents, moved for dismissal based on legislative immunity, which the court granted. The Governor, the remaining respondent, moved to dismiss the case, arguing he was not a proper party. The court denied this motion, finding the Governor’s role in appointing business court judges central to the dispute. The Oklahoma Association for Justice filed an amicus brief supporting Petitioners. The court assumed original jurisdiction, issued a temporary stay of the Act’s effectiveness, and heard oral arguments.The Supreme Court of the State of Oklahoma held that Petitioners had standing as both taxpayers and voters. The court found Senate Bill 632 unconstitutional because it violated Article VII, Section 9 of the Oklahoma Constitution by circumventing the requirement that district judges be elected by voters. The court further determined that the unconstitutional provisions were not severable from the rest of the Act, rendering the entire Act void and unenforceable. The petition for declaratory relief was granted, and the temporary stay remained in effect pending any rehearing. View "White v. Stitt" on Justia Law

A nursing home resident’s legal representative, acting under a durable power of attorney, sued a nursing home for alleged medical negligence during the resident’s stay. Upon admission, the representative signed several documents, including an agreement to arbitrate any disputes arising from the resident’s care. The representative later claimed not to recall signing the documents but did not dispute her signature. The nursing home moved to compel arbitration based on the signed agreement, which expressly stated it was governed by the Federal Arbitration Act (FAA).The District Court of McCurtain County, Oklahoma, held a hearing on the motion to compel arbitration. The court found that a valid arbitration agreement existed, signed by both an authorized agent of the nursing home and the legal representative. The court determined that the FAA applied due to the involvement of interstate commerce and that the Oklahoma Nursing Home Care Act’s (NHCA) prohibition of arbitration agreements was preempted by federal law. The court granted the nursing home’s motion to compel arbitration and stayed the judicial proceedings.The Supreme Court of the State of Oklahoma reviewed the case de novo. It affirmed the district court’s decision, holding that the FAA preempts the NHCA’s categorical prohibition of arbitration agreements in the nursing home context when interstate commerce is involved and the agreement expressly invokes the FAA. The court found the arbitration agreement was validly executed and not unconscionable, distinguishing this case from prior Oklahoma precedent and aligning with the United States Supreme Court’s decision in Marmet Health Care Center, Inc. v. Brown. The Supreme Court of Oklahoma affirmed the district court’s order compelling arbitration. View "Thompsonl v. Heartway Corp." on Justia Law

The plaintiff sought medical care for severe headaches and related symptoms from various providers in Oklahoma and Missouri, including Freeman Health System (FHS) and Dr. Gulshan Uppal in Joplin, Missouri. After multiple visits and treatments, she was ultimately diagnosed with serious neurological conditions and suffered lasting health consequences. She alleged that several healthcare providers, including FHS and Dr. Uppal, negligently diagnosed, treated, and discharged her.She filed suit in the District Court of Ottawa County, Oklahoma, naming multiple defendants. FHS and Dr. Uppal moved to dismiss for lack of personal jurisdiction, arguing their actions and contacts were insufficient for Oklahoma courts to exercise jurisdiction. The district court granted the motion, finding it lacked both general and specific personal jurisdiction over these defendants, primarily because the relevant treatment occurred in Missouri and the claims did not arise from FHS’s Oklahoma contacts. The Oklahoma Court of Civil Appeals affirmed this decision.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the district court erred by only considering whether the suit “arose out of” the defendants’ contacts with Oklahoma, and not whether it “related to” those contacts, as required by the two-pronged standard for specific personal jurisdiction clarified in Ford Motor Co. v. Montana 8th Judicial District Court. The Supreme Court found that the plaintiff met her burden regarding FHS’s contacts with Oklahoma, warranting further proceedings to determine if her claims “relate to” those contacts. However, the plaintiff failed to show sufficient contacts for personal jurisdiction over Dr. Uppal. The Supreme Court vacated the appellate court’s opinion, affirmed the district court’s dismissal of Dr. Uppal, reversed the dismissal of FHS, and remanded for further proceedings. View "Barfell v. Freeman Health System" on Justia Law

Several homeowners initiated a lawsuit against an individual, alleging conversion, trespass, outrage, reformation of restrictive covenants, quiet title, and seeking injunctive relief to prevent interference with their use of common areas in a real estate development. The defendant retained counsel and filed a timely answer. However, when the homeowners moved for summary judgment, the defendant’s attorney failed to respond or inform his client about the motion. The district court granted summary judgment for the homeowners, awarding substantial actual and punitive damages, as well as attorney’s fees, far exceeding the amount requested in the motion.After more than 30 days had passed since judgment, the defendant moved to vacate the judgment in the District Court of Cherokee County, Oklahoma, arguing that unavoidable casualty or misfortune, fraud, and irregularity had prevented him from defending the action. The district court held an evidentiary hearing and denied the motion to vacate. The defendant appealed, and the Court of Civil Appeals, Division III, affirmed the district court’s decision, finding that the defendant had not properly pled a valid defense and that his attorney’s negligence was imputed to him.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the attorney’s abandonment of the case without the client’s knowledge, combined with a breakdown in office procedures and lack of communication, constituted unavoidable casualty or misfortune under Oklahoma law. The court further found that the district court’s award of damages and attorney’s fees without a hearing or proper evidentiary support violated the defendant’s due process rights. The Supreme Court vacated the opinion of the Court of Civil Appeals, reversed the district court’s judgment, and remanded the case for further proceedings. It also vacated the appellate attorney fee award previously granted to the homeowners. View "Bjorkman v. Noble" on Justia Law

A dispute arose when Oklahoma Gas and Electric (OG&E) began providing retail electric service to a large cryogenic natural gas facility, the Chisolm Trail Plant, located in the certified territory of Oklahoma Electric Cooperative (OEC) in rural Grady County, Oklahoma. Under the Retail Energy Supplier Certified Territory Act (RESCTA), OEC holds exclusive rights to serve customers in this area, unless an exception applies. OG&E relied on the "Large Load" exception, which allows another supplier to serve a facility with an initial load of 1,000 kilowatts or more. To serve the Plant, OG&E connected to a third-party transmission line owned by Public Service Company of Oklahoma, rather than extending its own distribution system.After OG&E began service in May 2018, OEC filed an application with the Oklahoma Corporation Commission in August 2019, seeking to enjoin OG&E from serving the Plant, arguing that OG&E’s conduct violated RESCTA. The Commission, however, denied OEC’s request for injunctive relief, not by analyzing the statutory exception, but by finding that OEC’s claim was barred by the equitable defenses of laches, estoppel, and waiver, due to OEC’s delay in objecting and OG&E’s substantial investment in infrastructure.The Supreme Court of the State of Oklahoma reviewed the case and held that, under its recent decision in Oklahoma Gas & Electric Co. v. Oklahoma Corp. Comm’n (People’s), RESCTA’s Large Load exception does not permit a supplier to connect with third-party transmission lines to extend service into another supplier’s certified territory. However, because the holding in People’s applies only prospectively and not to existing service arrangements, OG&E is permitted to continue serving the Plant. The Supreme Court affirmed the Commission’s order allowing OG&E to continue providing retail electric service to the customer in OEC’s territory. View "OKLAHOMA ELECTRIC COOPERATIVE v. STATE ex rel. OKLAHOMA CORPORATION COMMISSION" on Justia Law

A former employee brought suit against her previous employer, alleging that she was terminated due to her mental and physical disabilities. The plaintiff had a history of cancer and mental health issues, and she was on short-term disability leave at the time of her termination. She claimed that her employer’s actions during her leave, including communications from supervisors and the circumstances of her termination, caused her severe emotional distress. The only claim she asserted was for intentional infliction of emotional distress, and she did not pursue any statutory discrimination claims.In the District Court of Cleveland County, the employer moved for summary judgment, arguing that the plaintiff’s claim was preempted by the Oklahoma Anti-Discrimination Act (OADA), which provides the exclusive remedy for employment discrimination claims. The trial judge initially granted summary judgment in favor of the employer, finding both that the plaintiff failed to show legally sufficient emotional distress and that her claim was preempted by the OADA. After the case was reassigned to a new judge, the plaintiff’s motion to vacate the summary judgment was granted, and the summary judgment order was set aside. The employer appealed this order.The Supreme Court of the State of Oklahoma reviewed the case and held that the OADA, as amended in 2011, provides the exclusive remedy for employment discrimination claims, preempting common law tort claims such as intentional infliction of emotional distress when they arise from the same facts as a discrimination claim. The Court found that the plaintiff’s claim was entirely based on alleged discriminatory conduct covered by the OADA and did not allege any independent, highly personal tortious conduct. The Supreme Court reversed the order vacating summary judgment and remanded with instructions to reinstate summary judgment in favor of the employer. View "Baughman v. World Acceptance Corp." on Justia Law