Justia Oklahoma Supreme Court Opinion Summaries

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Appellant John Doe filed suit against Appellees, a church and its minister, alleging torts and breach of contract after he was baptized and notice of his baptism was published on the internet, resulting in his alleged kidnapping and torture by extremists while travelling in Syria. The trial court sustained Appellees' motion to dismiss for lack of subject matter jurisdiction. Appellant appealed. The question presented for the Oklahoma Supreme Court’s review was whether the church autonomy doctrine, rooted in the First Amendment to the United States Constitution, barred the courts from considering Appellant’s claims against Defendants-Appellees. The Supreme Court held that it does. View "Doe v. First Presbyterian Church U.S.A. of Tulsa" on Justia Law
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Petitioner Rodney Stanley Brown was employed by Respondent Claims Management Resources (CMR) as a claims adjuster. Brown suffered personal injury to his left knee. At the time Brown was injured, he finished his workday, clocked out, was leaving the office for the day when he fell while descending an interior stairwell. Brown's work area was on the second floor of the building where he worked, and CMR occupied the entire floor. Brown was unable to conclusively identify any factor that might have caused his fall. While admitting an injury occurred, CMR asserted Brown's injury was not compensable within the meaning of the Administrative Workers' Compensation Act (AWCA). A hearing on the matter was held before the Administrative Law Judge, and after considering the parties' stipulations, evidence, and arguments, the Administrative Law Judge concluded that Brown had failed to meet his burden of proving by a preponderance of the evidence that he suffered a compensable injury within the meaning of the AWCA. The Supreme Court concluded after its review that Brown was acting in the course and scope of his employment, and his injury was a compensable injury. The Workers' Compensation Commission’s interpretation of 85A O.S. Supp. 2013 sections 2(9) & (13) was legally incorrect and its order denying compensability was clearly erroneous in view of the competent evidence presented. Because relief was available on alternative grounds, the Court did not reach the constitutional issues presented. View "Brown v. Claims Management Resources, Inc." on Justia Law

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Defendant Century Surety Company (Century) issued a Commercial Lines Policy to Plaintiff Siloam Springs Hotel, L.L.C. (Siloam). This policy included general liability insurance coverage of Siloam's hotel in Siloam Springs, Arkansas, for the policy period from November 13, 2012, through November 13, 2013. The insuring agreement of the general liability coverage form provided that Century would pay sums the insured was legally obligated to pay as damages because of bodily injury to which the insurance applies and that Century would have the right and duty to defend the insured against any suit seeking such damages. On January 17, 2013, several guests inside of the hotel allegedly suffered bodily injury due to carbon monoxide poisoning. The carbon monoxide allegedly escaped into the air due to leakage from the hotel's indoor swimming pool heater. Siloam sought coverage under its policy from Century, which Century denied based on an Indoor Air Exclusion at issue. The United States District Court for the Western District of Oklahoma certified a single question of Oklahoma law to the Oklahoma Supreme Court under the Revised Uniform Certification of Questions of Law Act, 20 O.S. 2011 sections 1601-1611: “Does the public policy of the State of Oklahoma prohibit enforcement of the Indoor Air Exclusion, which provides that the insurance afforded by the policy does not apply to ‘Bodily injury', 'property damage', or 'personal and advertising injury' arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause?” The Oklahoma Supreme Court answered the question in the negative. View "Siloam Springs Hotel, LLC v. Century Surety Co." on Justia Law

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Prior to filing condemnation proceedings the Appellee Oklahoma Department of Transportation (ODOT) offered Appellants, Cedars Group, L.L.C., A. Sam Coury and Bush, Ltd. d/b/a Deer Creek Texaco, (collectively, Coury Defendants), $562,500.00 for the acquisition of certain real property. The offer was not accepted and ODOT commenced two condemnation proceedings. In one, a commissioners' report estimated the value of just compensation for the property to be $285,000.00. In the second proceeding, the value of just compensation was estimated as $177,500.00. The combined value of the two commissioners' awards totaled $462,500.00. The Coury Defendants hired Gregg Renegar's law firm to provide representation in the condemnation proceedings. Pursuant to the firm’s attorney-client agreement, the Coury Defendants agreed to pay forty percent of the difference between an award and jury verdict, plus any attorney’s fees allowed by the court. A jury trial was held, and the jury awarded just compensation of $525,000 for the two tracts. Defendants applied for attorney fees. The trial court determined Defendants were not entitled to an award of fees because they never actually incurred any. In the end, the trial court awarded appraisal fees but denied reasonable attorney, engineering and expert witness fees, costs and expenses of Defendants. The Supreme Court affirmed in part and reversed in part; the case was remanded for a determination of reasonable attorney fees, engineering and expert witness fees, and costs. View "Oklahoma ex rel. Dept. of Trans. v. Cedars Group, LLC" on Justia Law

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Plaintiff-appellant Malinda Falcone brought an insurance claim against defendants-appellees for payment of her emergency room medical expenses. Her claim was made pursuant to the Uninsured/Underinsured Motorist (UM) provisions of her mother's automobile insurance policy following the injuries she sustained as a passenger in her mother's car when an uninsured driver ran a stop sign and collided with them. Defendants initially questioned the decision to refer Plaintiff to the level 2 trauma center of the emergency room and refused to pay the bill Plaintiff received from the OU Medical Center trauma center. After nearly a year of offers and rejections, Plaintiff sued for breach of the implied duty of good faith and fair dealing for failing to pay her trauma room "compensatory damages" as required under the policy. The trial court granted summary judgment in favor of defendants and denied Plaintiff's motion for new trial. After review, the Supreme Court held that it was a question for the trier of fact whether defendants showed a lack of good faith in handling Plaintiff's claim for payment. The trial court erred in granting summary judgment in defendants' favor, holding as a matter of law that defendants did not commit the tort of bad faith. View "Falcone v. Liberty Mutual Ins. Co." on Justia Law

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After the Oklahoma Board of Medical Licensure and Supervision (Board) began investigating plaintiff-appellant, Dr. Steven Anagnost, he filed a lawsuit against several doctors and their professional companies (collectively, defendants).Anagnost alleged negligence, abuse of process, tortious interference with business relations, intentional infliction of emotional distress, and defamation. When Anagnost discovered additional information from the Board's file, he filed an amended petition asserting additional claims against the Board and certain Board members. The amended petition was filed after the newly enacted Oklahoma Citizens Participation Act, (the OCPA) became effective. The defendants sought dismissal of the lawsuit pursuant to the new dismissal provisions of the OCPA. The trial court applied the OCPA, and dismissed the negligence claims against the defendants, but denied all other requested relief. The defendants appealed and the Court of Civil Appeals affirmed in part, reversed in part, and remanded with directions. The Oklahoma Supreme Court granted certiorari to address the dispositive issue of whether the OCPA could be applied retroactively. The Court held that it could not. View "Anagnost v. Tomecek" on Justia Law

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Appellants Bruce Schultz and Jared Bruce mutually sought to vacate their adult adoption granted ten years prior. The issue in this case was whether the trial court lacked authority to vacate an adult adoption where both parties sought the termination of parental rights as competent adults. The trial court opined that because the Oklahoma Adoption Code, 10 O.S. 2011, section 7507-1.1, neither authorized nor prohibited the vacation of adult adoptions, it lacked authority to vacate the existing order. Appellants appealed to the Oklahoma Supreme Court directly, and the Supreme Court retained the first impression matter. Based on the Legislature's provisions in granting adult adoptions, parallel provisions for vacating adoptions of minor children, and the overall intent of the Adoption Code, the Supreme Court found an error warranting remand to the trial court to rehear Appellants' petition. As the trial court correctly found consent and competency of the parties, upon remand it needed only conduct a best-interest determination in deciding the matter. "With neither bad faith nor fraudulent motive of the parties, we find no evidence to suggest that the termination of rights herein would not serve their best interests." View "In the Matter of the Termination of Parental Rights of Schultz" on Justia Law

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The administrator of a decedent's estate appealed an interlocutory district court order compelling the administrator to file a federal estate tax return for the decedent's estate and elect portability of the Deceased Spousal Unused Exclusion Amount pursuant to 26 U.S.C.A. 2010. The surviving spouse sought the order, and benefits from the portability election. The administrator argued the district court erred on several grounds: lack of jurisdiction; issues with federal preemption; the surviving spouse's lack of standing; and that the order was contrary to an antenuptial agreement entered into between the surviving spouse and the decedent. After review, the Oklahoma Supreme Court found no reversible error and affirmed. View "In the matter of Estate of Vose" on Justia Law
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The issue this case presented for the Oklahoma Supreme Court's review centered on the constitutionality of SB 1848, passed by the Legislature and signed into law by the Governor on May 28, 2014. The effective date of the legislation was November 1, 2014. This legislation contained one section with twelve separate and unrelated sub-sections, A to L. "Under the guise of the protection of women's health," SB 1848 required an abortion facility to have a physician on premises who also has hospital admission privileges within thirty miles of the facility, on any day an abortion is performed. The Supreme Court reversed the district court's findings and held the statute unconstitutional because it created an undue burden on a woman's access to abortion, violating protected rights under the federal Constitution, and also under the Oklahoma single subject rule. View "Burns v. Cline" on Justia Law

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The Oklahoma Turnpike Authority (Authority) wanted to issue revenue bonds for use in the construction of certain turnpike projects. Pursuant to 69 O.S.2011, section 1718, the Authority filed an application with the Oklahoma Supreme Court seeking approval of the proposed bonds. The Protestant, Jerry Fent, challenged the validity of the requested bonds. After review of the Protestant’s arguments to challenge the bonds, the Supreme Court determined the proposed bond issue was properly authorized. The Court found that valid notice of this application was given and that the Authority and the Protestant were fully heard. The Protestant advanced no legally or factually supportable reasons to disapprove the application. Accordingly, the Authority's application was granted. View "In the Matter of the Application of the Okla. Turnpike Authority" on Justia Law