Justia Oklahoma Supreme Court Opinion Summaries

A 21-year-old college student experienced COVID-19 symptoms and subsequently developed chest pain, shortness of breath, and lightheadedness. After testing positive for COVID-19 at urgent care, he sought emergency treatment at a hospital where the physician noted pleuritic chest pain and performed diagnostic tests, including an EKG and chest x-ray, both showing abnormalities. Due to hospital COVID-19 protocols, his mother was unable to convey his family history of a blood clotting disorder to the physician. The patient was discharged without a pulmonary embolism diagnosis and died twenty days later from cardiac arrest caused by a pulmonary embolism with underlying COVID-19.The parents filed a wrongful death and medical negligence suit in the District Court of Oklahoma County against the hospital, physician, and emergency services group. The defendants argued immunity under both Oklahoma’s COVID-19 Public Health Emergency Limited Liability Act and the federal Public Readiness and Emergency Preparedness Act (PREP Act). The trial court denied summary judgment on both immunity claims, rejected the PREP Act defense at trial, denied the Oklahoma COVID-19 Act immunity as a matter of law, and granted a directed verdict for the parents on intervening/supervening causation. The jury found negligence, awarded damages, and attributed contributory negligence to the decedent.The Supreme Court of the State of Oklahoma held that the defendants are immune from liability for ordinary negligence under Oklahoma’s COVID-19 Act because the patient was impacted by the facility’s COVID-19 policies, and the trial court erred by not granting a directed verdict on this immunity. However, the Court held that PREP Act immunity does not apply because the alleged injury was not causally related to the administration or use of covered countermeasures. The Court also affirmed the trial court’s handling of intervening/supervening causation. The judgment of the district court was reversed and the case remanded for a new trial. View "BURGESS v. INTEGRIS HEALTH EDMOND, INC." on Justia Law

After a hailstorm damaged its property, a food and resource center submitted a claim to its property insurer. The insurer hired an engineering company to inspect the property and report its findings. Following the inspection, the insured filed a lawsuit against the insurer for breach of contract and bad faith, and against its insurance agent for misrepresentation. Later, the insured amended its petition to add claims against the engineering company for tortious interference with contract and civil conspiracy, alleging the company’s inspection and reporting were biased to support the insurer’s position.The District Court of Payne County reviewed the engineering company’s motion to dismiss the claims against it. The court denied the motion, allowing the tortious interference and civil conspiracy claims to proceed. The engineering company petitioned for interlocutory review, and the district court certified its order, expressing that immediate appeal would materially advance the litigation’s resolution. The Supreme Court of the State of Oklahoma granted certiorari to consider whether the insured’s claims against the engineering company were legally viable.The Supreme Court of the State of Oklahoma held that the claims against the engineering company fail as a matter of law. The Court determined that, because the engineering company acted as a representative for the insurer when conducting the inspection, it cannot be liable for tortious interference with contract or civil conspiracy under Oklahoma law. The Court emphasized that such representatives are privileged in their actions and that the insurer’s duties are non-delegable. Accordingly, the Court reversed the district court’s judgment and remanded the matter for further proceedings consistent with its opinion. View "COMMUNITY RESOURCING, INC. v. BERKSHIRE HATHAWAY SPECIALTY INSURANCE" on Justia Law

A bus accident involving the Choctaw Nation resulted in a lawsuit seeking damages for deceased and injured passengers. At the time, the Nation was insured by three companies: Occidental Insurance Company, Hudson Insurance Company, and General Star Indemnity Company. Occidental paid its policy limits and was not involved in this litigation. Hudson and General Star both contributed to settlement payments and defense costs, each asserting that its policy was excess and the other was primary. General Star sought reimbursement from Hudson for settlement sums paid, arguing that Hudson’s policy was primary. Hudson contended its policy was excess and only liable after other coverage was exhausted.The District Court granted summary judgment to General Star, ordering Hudson to reimburse General Star for its payments. The court also awarded General Star prejudgment interest under 36 O.S. § 3629 (B) after a post-judgment motion. Hudson appealed, and the Court of Civil Appeals affirmed the district court’s rulings regarding policy status and the award of prejudgment interest, but reversed the requirement that judgment be paid within thirty days. Hudson then sought certiorari review from the Supreme Court of Oklahoma on the issues of policy characterization and prejudgment interest.The Supreme Court of the State of Oklahoma vacated the Court of Civil Appeals’ opinion. It affirmed the District Court’s grant of summary judgment in favor of General Star and denial of summary judgment to Hudson, holding that Hudson’s policy was primary and General Star’s was excess. However, the Supreme Court reversed the award of prejudgment interest, finding that Section 3629 (B) does not allow a prevailing insurer to recover prejudgment interest in a coverage dispute between insurers. The order of final judgment was also reversed, and the case was remanded for further proceedings. View "GENERAL STAR INDEMNITY CO. v. HUDSON INSURANCE CO." on Justia Law

A couple hired a mobile home transport company to move their mobile home to a new location. The company, Brown & Son, subcontracted the actual move to another individual, Jason Gaston. During transport, the home sustained significant damage when the wheels became stuck, and efforts to move it led to further harm. Before the move, the couple spoke with their insurance agent, who assured them their existing policies would cover any transport-related loss. However, after the damage, their insurers denied the claim, citing exclusions for damages incurred during transport.The couple then sued their insurers and their agent, Michelle Schaefer, for breach of contract, bad faith, and misrepresentation regarding their insurance coverage. They did not bring claims against Brown & Son or Gaston. In response, Schaefer, as a third-party plaintiff, sought contribution or indemnity from Brown & Son and Gaston, arguing that if she was found liable for the couple’s losses, those parties should share responsibility. The District Court of Oklahoma County granted summary judgment to Brown & Son, concluding that statutory changes in Oklahoma law had abolished joint and several liability and, by extension, the right to contribution in this context. The Oklahoma Court of Civil Appeals affirmed that decision.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The Court vacated the decision of the Court of Civil Appeals but affirmed the trial court’s grant of summary judgment to Brown & Son, though on different grounds. The Supreme Court held that contribution was unavailable because the alleged injuries caused by Brown & Son (physical damage to the mobile home) and Schaefer (losses from lack of insurance coverage) were not the same injury as required by statute. Therefore, Brown & Son and Schaefer were not jointly or severally liable for the same injury, and no right of contribution existed. View "RICHARDS v. FOREMOST INSURANCE CO." on Justia Law

Several years ago, an individual, both personally and as trustee for several land trusts, executed three promissory notes in favor of a bank, secured by mortgages on properties in both Tulsa and Washington Counties, Oklahoma. The notes were cross-collateralized, meaning all properties secured all notes. After the borrower defaulted in 2014, the bank initiated foreclosure actions in both counties but dismissed the Tulsa County case, proceeding only in Washington County. There, the court entered judgment on the notes, foreclosed the Washington County property, and, after its sale did not satisfy the full debt, entered an “Agreed Deficiency Judgment” against the borrower for the remaining balance.Subsequently, the bank filed a new foreclosure action in Tulsa County, seeking to foreclose the Tulsa properties based on the same notes and attaching the prior deficiency judgment. The Tulsa County District Court granted summary judgment to the bank, finding the action timely because the deficiency judgment constituted a written acknowledgment of debt, thus reviving the statute of limitations under 12 O.S. § 101. The Court of Civil Appeals affirmed, agreeing that the statute of limitations had been extended and that the mortgage liens were still valid.The Supreme Court of the State of Oklahoma reviewed the case. It held that once the promissory notes were reduced to judgment in Washington County, they ceased to exist as independently enforceable contracts, and the bank's remedies became limited to enforcement of the judgment, not the original notes or mortgages. The Court concluded that 12 O.S. § 101, which revives contract-based claims upon written acknowledgment, did not apply to judgments. Therefore, the mortgage liens on the Tulsa properties were extinguished when the statute of limitations on the notes expired, and the subsequent deficiency judgment could not revive them. The Supreme Court vacated the Court of Civil Appeals’ opinion, reversed the Tulsa County District Court’s judgment, and remanded with instructions to enter judgment for the defendants. View "RCB BANK v. STITT" on Justia Law

The case concerns an agreement between the City of Tulsa and the Muscogee (Creek) Nation, made in connection with ongoing federal litigation over whether Tulsa has criminal jurisdiction over Native Americans for conduct within the Nation's reservation. Through a settlement, Tulsa agreed not to exercise criminal jurisdiction over Native Americans on the reservation, to dismiss pending prosecutions in municipal court, and to refrain from future prosecutions of Native Americans for acts occurring there. The State of Oklahoma, through its Governor, challenged the validity of this settlement, arguing it was entered into without necessary state approvals.Following the settlement, the United States District Court for the Northern District of Oklahoma declined to rule on the agreement’s validity, finding that whether the agreement was lawful was a matter of state law. The federal court also denied the State’s motion to intervene and ultimately dismissed the federal litigation after the parties stipulated to dismissal in light of their settlement.The Supreme Court of the State of Oklahoma assumed original jurisdiction to decide whether Tulsa’s agreement with the Nation was valid under state law. The court concluded that although cities may enter into cooperative agreements with tribal governments, state law requires such agreements to be approved by both the Governor and the Joint Committee on State-Tribal Relations. The court held that Tulsa’s settlement was a new and independent agreement—not merely an extension of a prior cross-deputization agreement—and lacked the mandatory statutory approvals. The court issued a writ of mandamus compelling Tulsa to secure those approvals if it wishes to proceed and declared the settlement unenforceable as a matter of law until such approvals are obtained. View "STATE OF OKLAHOMA ex rel. STITT v. CITY OF TULSA" on Justia Law

A trust established to provide self-insurance coverage for Oklahoma public schools entered into agreements with various school districts, requiring member schools to make regular contributions. In April 2019, the trust’s Board voted to amend its agreement to increase reserve contributions, and submitted the amendment to the Attorney General for approval as required by state law. After the Attorney General rejected the proposed amendment and advised that a new vote was needed for a revised agreement, the Board scheduled a meeting for June 12, 2019. Although the agenda for the meeting was posted in advance, it did not include the Board’s vote on adopting and submitting the revised agreement, but instead listed a generic “New Business” item. At the meeting, the Board voted under “New Business” to adopt and submit the revised agreement, which was later approved by the Attorney General.The District Court of Cleveland County reviewed the trust’s claims against the school districts for failure to pay invoices under the amended agreement and considered cross-motions for summary judgment addressing compliance with Oklahoma’s Open Meeting Act (OMA). The respondent school districts argued that the Board’s actions violated the OMA because the agenda failed to give proper notice of the substantive vote and the Secretary of State was not notified of the rescheduled meeting. The District Court granted partial summary judgment in favor of the school districts, finding a willful violation of the OMA, and certified the order for interlocutory review.The Supreme Court of the State of Oklahoma applied a de novo standard of review and affirmed the District Court’s order. The Court held that the Board violated the OMA by voting on the revised agreement under “New Business” when the matter was known more than 24 hours in advance and should have been included in the agenda. This constituted a willful violation, invalidating the Board’s action under the OMA. View "OKLAHOMA SCHOOLS RISK MANAGEMENT TRUST v. LEXINGTON SCHOOL DISTRICT" on Justia Law

A federally recognized tribe in Oklahoma has experienced ongoing leadership disputes for nearly two decades, with multiple factions vying for control. Since 2007, the tribe has failed to hold valid elections, instead appointing interim leaders, which has led to repeated litigation in tribal, federal, and now state courts. Recently, rival claimants conducted separate elections, resulting in competing assertions of authority and control over tribal assets, with the Bureau of Indian Affairs declining to recognize any leader due to the unresolved internal conflict.The Okfuskee County District Court became involved after one faction, supported by its purported Business Committee, filed for a temporary restraining order against another group for trespass and sought declaratory relief as to the legitimate tribal leadership. The court issued an emergency restraining order and denied a motion to dismiss for lack of subject matter jurisdiction, finding that the Business Committee recognized by tribal courts was the proper authority and that the dispute concerned civil trespass, not internal governance.The Supreme Court of the State of Oklahoma was asked to assume original jurisdiction and issue a writ of prohibition against the district court’s proceedings. The Supreme Court of Oklahoma held that the dispute in the district court was, in fact, an unresolved intratribal leadership conflict that would require the state court to interpret tribal law and governance structures. The court determined that such intratribal disputes are nonjusticiable in state courts due to principles of tribal sovereignty and self-government, and that the purported waiver of sovereign immunity by one faction could not confer jurisdiction when the authority of that faction itself was contested. Accordingly, the Supreme Court of Oklahoma granted the writ of prohibition, assumed original jurisdiction, and ordered the district court to dismiss the case for lack of subject matter jurisdiction. View "ANDERSON v. PARRISH" on Justia Law

A group of plaintiffs challenged the Oklahoma State Board of Education’s adoption of the 2025 Social Studies Standards, arguing the standards were improperly enacted and violated statutory and constitutional rights, including compelled viewpoint-specific speech in public education. After the Board approved the standards, the plaintiffs sought declaratory and injunctive relief to prevent their implementation, claiming both procedural errors in their adoption and substantive harms to students, parents, and teachers.The District Court for Oklahoma County heard the case and granted the defendants’ motions to dismiss, determining that the plaintiffs were unlikely to succeed and that their claims about the Oklahoma Administrative Code were incorrect. The District Court also denied the plaintiffs’ request for a preliminary injunction. The plaintiffs appealed, raising issues about administrative procedures, standing, and the denial of an opportunity to amend their petition.While the appeal was pending, the Oklahoma Supreme Court in Randall v. Fields, 2025 OK 91, held that the 2025 Social Studies Standards could not be enforced due to violations of the Oklahoma Open Meeting Act, rendering the standards void. In light of this, the Supreme Court of the State of Oklahoma determined that the plaintiffs’ claims for relief were now moot because the challenged standards no longer existed. The Court found that neither the “broad public interest” nor “capable of repetition yet evading review” exceptions to mootness applied. Accordingly, the Supreme Court dismissed the appeal as moot, reversed the District Court’s judgment, and directed the lower court to dismiss the plaintiffs’ petition without prejudice due to mootness. View "FORD v. THE OKLAHOMA STATE DEPARTMENT OF EDUCATION" on Justia Law

A patient who had recently undergone heart surgery was transported to a hospital after experiencing chest pain. Upon arrival, hospital staff inserted a second intravenous line in her left hand for a CT scan with contrast. During the procedure, contrast agent leaked into the tissue of her hand, and hospital staff followed their protocol to address the infiltration, including administering an antidote and later performing a surgical procedure to drain a hematoma. The patient subsequently alleged that she suffered permanent injury, including Chronic Regional Pain Syndrome, as a result of the infiltration.The patient filed a medical malpractice suit against the hospital, relying on a registered nurse as her expert witness to opine on the standard of care and causation. The District Court of Tulsa County granted summary judgment in favor of the hospital, finding that the nurse was not qualified to testify as to the physician’s standard of care, and that there was insufficient evidence to establish causation. The patient appealed, and the Oklahoma Court of Civil Appeals reversed, holding that a factual dispute remained regarding whether non-physician hospital employees were negligent and caused the patient’s injuries.The Supreme Court of the State of Oklahoma reviewed the case and concluded that the patient failed to produce a qualified expert to testify regarding the standard of care for physicians, and that the nurse’s opinions could not establish hospital physician negligence. The Court further held that hospital nurses cannot be liable for following physician orders absent evidence that the orders were obviously negligent, and that the patient failed to present proper expert testimony to establish causation between any alleged breach and her injury. The Supreme Court vacated the opinion of the Court of Civil Appeals and affirmed the judgment of the District Court, effectively ruling in favor of the hospital. View "BEAN v. ST. FRANCIS HOSPITAL" on Justia Law