Justia Oklahoma Supreme Court Opinion Summaries

A man was killed in a motor vehicle accident while working for Rent-A-Center. His widow and the mother of his minor child sued the driver responsible for the accident and other related parties in the District Court of Bryan County, Oklahoma. The employer and its insurance carrier, having paid statutory workers' compensation death benefits to the widow and child, were allowed to intervene, seeking reimbursement for the death benefits from any recovery against the tortfeasor, as authorized by 85A O.S.2014, § 43.Plaintiffs moved for summary judgment, arguing that Section 43 was unconstitutional under Article 23, section 7 of the Oklahoma Constitution. The District Court granted summary judgment in favor of the plaintiffs, finding the statute unconstitutional as applied to death benefits. The employer and insurer appealed, and the Court of Civil Appeals, Division I, reversed the trial court’s order, holding Section 43 constitutional based on precedent and persuasive authority from other jurisdictions. Plaintiffs then petitioned for certiorari review by the Oklahoma Supreme Court, which was granted.The Supreme Court of the State of Oklahoma conducted a de novo review and held that 85A O.S.2014, § 43 is constitutional and does not violate Article 23, section 7 of the Oklahoma Constitution. The court clarified that Section 43 does not abrogate the right of action for wrongful death but rather apportions recovery between dependents and the employer or insurer who paid benefits. The opinion of the Court of Civil Appeals and the trial court’s order were both vacated, and the case was remanded for further proceedings consistent with the Supreme Court’s decision. View "ALEXANDER v. DUONG" on Justia Law

Two minor children were the subjects of a step-parent adoption petition filed by their mother and step-father, seeking to proceed without the consent of the children’s natural father. The mother and step-father argued that the father’s consent was not required because he had both failed to provide court-ordered child support and failed to maintain a substantial and positive relationship with the children for twelve consecutive months out of the fourteen months preceding the petition. Evidence at the hearing included records of minimal child support payments, testimony and phone records showing limited contact between father and children, and some text messages between father and son. The father claimed his attempts at communication were obstructed by the mother, and he communicated with the children through indirect means and social media, though no physical evidence supported the Snapchat communications.The District Court of Caddo County found that the father's consent was unnecessary for the adoption because he failed to maintain a substantial and positive relationship with the children and did not take sufficient legal action to overcome any denial of opportunity to maintain such a relationship. The court held all other matters in abeyance. The father appealed, and the Oklahoma Court of Civil Appeals reversed the district court, concluding there was insufficient evidence of willfulness in the father’s failure to pay support and that the mother had thwarted the father’s efforts to maintain a relationship.The Supreme Court of the State of Oklahoma vacated the Court of Civil Appeals’ opinion and affirmed the district court’s order. The Supreme Court held that clear and convincing evidence supported the finding that the father failed to maintain a substantial and positive relationship with both children during the statutory period, and he did not take sufficient legal action to remedy denial of opportunity. The father’s consent to adoption was therefore unnecessary under Oklahoma law, and the case was remanded for further adoption proceedings. View "In the Matter of the Adoption of C.J.B." on Justia Law

An employee with a long tenure at a state agency suffered a heart attack and was subject to permanent medical restrictions preventing him from performing his original job duties at a coal-fired power plant. The agency accommodated him for two years with a temporary assignment and ultimately offered him a permanent position that met his medical restrictions, but at a lower hourly wage. The employee did not respond to the offer and was subsequently terminated.The employee sought review of his termination before the Civil Service Division of the Office of Management and Enterprise Services (OMES). An administrative law judge found he failed to meet his burden to prove that the agency had no reasonable basis for his termination, and OMES adopted that decision. The employee then sought judicial review in the District Court of Mayes County, which reversed OMES’s order. The district court found that the employee had a substantial interest in his employment and that the statutory and regulatory procedures for termination under 62 O.S. § 34.301 violated due process. The district court also concluded that the agency lacked a reasonable basis to terminate the employee and ordered further proceedings.The Supreme Court of the State of Oklahoma reviewed the case. It held that the Civil Service Modernization Act does not create a constitutionally protected property interest in continued public employment for state employees, so due process protections are not triggered by terminations under this statute. The Court further held that the district court erred in reweighing the evidence and misapplied the statutory burden of proof: the employee did not prove there was no reasonable basis for his termination. The Supreme Court reversed the district court’s judgment and affirmed OMES’s final agency order upholding the termination. View "TURNER v. OKLAHOMA GRAND RIVER DAM AUTHORITY" on Justia Law

Several business entities collectively known as the Merit Entities entered into loan agreements with International Bank of Commerce (IBC Bank) to finance the expansion of an auto dealership group. After discovering alleged fraudulent conduct by the dealership’s operator and his subsequent death, the Merit Entities entered negotiations with IBC Bank to restructure their debt, resulting in new loan agreements in October 2020 containing arbitration provisions with an anti-waiver clause. Despite ongoing disputes regarding outstanding debt and the validity of certain contract terms, the central issue on appeal was whether these disputes should be resolved in court or through arbitration.After the Merit Entities filed suit in the District Court, IBC Bank responded with both a motion to dismiss and an alternative motion to compel arbitration, citing the anti-waiver provision. The trial court denied the motion to dismiss in part and, following an evidentiary hearing, compelled arbitration, finding the arbitration agreement enforceable and applicable to the plaintiffs’ claims. On appeal, the Oklahoma Court of Civil Appeals reversed the trial court’s decision, holding that IBC Bank’s participation in litigation constituted a waiver of its right to arbitrate.The Supreme Court of the State of Oklahoma reviewed the case de novo and vacated the opinion of the Court of Civil Appeals, affirming the District Court’s order compelling arbitration. The Court held that IBC Bank did not waive its right to arbitrate because its conduct fell within the scope of activity expressly permitted by the anti-waiver provision in the arbitration agreement. Additionally, the Court found that the Merit Entities failed to establish fraudulent inducement specifically directed at the arbitration provisions. The parties’ disputes must therefore be resolved in arbitration as agreed. View "MERIT HOLDINGS v. INTERNATIONAL BANK OF COMMERCE" on Justia Law

Three transgender individuals sought to amend the sex designations on their Oklahoma birth certificates to align with their gender identities. They obtained state court orders directing these changes, but when presented to the Oklahoma State Department of Health, the applications were denied. The denial was based on an executive order issued by the Governor, which instructed the agency to cease amending birth certificates in ways not explicitly permitted by Oklahoma law.Plaintiffs filed suit in the United States District Court for the Northern District of Oklahoma, raising equal protection and due process claims against state officials. The District Court granted the defendants’ motion to dismiss, and plaintiffs appealed to the United States Court of Appeals for the Tenth Circuit. The Tenth Circuit affirmed dismissal of the due process claim but reversed on the equal protection claim. Defendants sought certiorari in the United States Supreme Court, which issued a Grant, Vacate, Remand order directing the Tenth Circuit to reconsider in light of United States v. Skrmetti, 605 U.S. 495 (2025). Subsequently, the Tenth Circuit certified three questions of Oklahoma law to the Supreme Court of Oklahoma.The Supreme Court of the State of Oklahoma held that Oklahoma Statute 63 O.S. § 1-321, as amended by § 1-321(H), prohibits changes to the sex designation on an Oklahoma birth certificate. The court further determined that neither current nor prior versions of the statute have ever permitted such changes, whether based on gender identity or otherwise. The answers to the certified questions were: 1) yes, the statute prohibits changes; 2) no, it has never permitted such changes; and 3) no, it does not now nor has ever permitted changes based on gender identity. View "FOWLER v. STITT" on Justia Law

The plaintiffs purchased a residential lot from a developer and later alleged that defective grading and drainage in the subdivision caused water and erosion damage to their property. They claimed that the developer and seller deviated from an approved drainage plan, redirecting stormwater onto their lot. The plaintiffs discovered the source of the problem several years after purchasing the property, following a heavy rainstorm. Their claims included negligence, breach of contract, and breach of the implied warranty of workmanlike construction.The District Court of Oklahoma County conducted a bench trial. After the plaintiffs rested their case, the defendants moved for a directed verdict and argued that the tort and warranty claims were barred by Oklahoma’s ten-year statute of repose (12 O.S. § 109), and the contract claim was barred by the five-year statute of limitations (12 O.S. § 95). The trial court found that the improvement causing the harm was substantially completed more than ten years before suit, and that the contract claim accrued on the date the lot was conveyed. The trial court entered judgment for the defendants on all claims.The Supreme Court of the State of Oklahoma reviewed the appeal. It held that the statute of repose begins to run upon substantial completion of the specific improvement alleged to have caused harm, not the completion of the overall development. The only evidence of substantial completion was uncontroverted, showing completion more than ten years before suit, barring the tort claims. The implied warranty and contract claims were also time-barred by the statute of limitations, and Turner & Company was not a party to the contract. The judgment of the District Court was affirmed. View "ESCH v. TURNER & COMPANY, INC." on Justia Law

On a cold, wet day, the plaintiff slipped and fell on black ice in the parking lot of a retail store, sustaining serious injuries. He brought a negligence action against the store, alleging that it failed to keep its premises reasonably safe for invitees. To prove that the store had notice of the dangerous condition, the plaintiff relied on evidence that a store employee had slipped on black ice approximately ten feet away, on a different side of a parking lot island, nearly an hour earlier. After the earlier fall, employees treated that area with salt or sand, but the plaintiff fell in a different spot. There was no evidence that the patch of ice that caused the plaintiff’s injury was present or reported before his fall, and several people walked over that area without incident between the two falls.A jury in the District Court of Oklahoma County found in favor of the plaintiff, awarding damages for pain and suffering and finding the store 95% negligent. The trial court admitted evidence of the earlier fall and denied the store’s motion for a directed verdict. The Court of Civil Appeals affirmed, finding that the circumstances of the falls were sufficiently similar and close in proximity for the earlier fall to be admissible to establish notice of the hazard, and concluded that the store owed a duty of care.The Supreme Court of the State of Oklahoma reversed. The court held that the earlier fall was not admissible under the governing standard, as it did not occur in the same place or under the same conditions as the plaintiff’s fall. Without admissible evidence that the store had notice of the specific hazard, the court concluded there was no duty owed to the plaintiff, and thus the negligence claim failed as a matter of law. The Supreme Court vacated the opinion of the Court of Civil Appeals, reversed the district court's judgment, and remanded with directions to enter judgment for the store. View "RAMIREZ v. WAL-MART STORES EAST, LP" on Justia Law

After a motor vehicle accident in October 2020, Maryann Thomas sought uninsured/underinsured motorist coverage from Liberty Mutual Insurance Company. She filed a lawsuit in March 2021. Liberty’s legal representation changed several times, with attorney transitions and withdrawals occurring between law firms in 2021 and 2022. Thomas sent requests for admission to Liberty’s previous counsel in June 2022, but Liberty’s new attorneys were not notified nor served with these requests. Thomas’s counsel did not follow up or inform the new attorneys about the requests, and Liberty did not respond.Thomas later moved for summary judgment, arguing that Liberty’s failure to respond meant the requests were deemed admitted under Oklahoma law, establishing liability for coverage. Liberty’s new counsel asserted they had no knowledge of the requests until Thomas moved for summary judgment a year later, asked the court to allow withdrawal of the admissions, and opposed summary judgment. The District Court of Oklahoma County granted summary judgment to Thomas based on deemed admissions, finding liability, and denied Liberty’s motion for summary judgment. The district court certified its order for immediate appeal.The Supreme Court of the State of Oklahoma reviewed the certified interlocutory order. It held that the district court abused its discretion by refusing to allow Liberty to withdraw the admissions. The Supreme Court found that permitting withdrawal would serve the presentation of the merits and that Thomas was not prejudiced, especially given the early stage of litigation and notice of disputed coverage. The Court reversed the district court’s order granting summary judgment to Thomas and remanded with instructions to allow Liberty to withdraw the admissions. View "THOMAS & GOZA v. LIBERTY MUTUAL INSURANCE CO." on Justia Law

A physician reported another doctor to the Oklahoma Board of Medical Licensure and Supervision for allegedly performing a wrong-site surgery. The Board initiated disciplinary proceedings but ultimately dismissed the complaint after a hearing. Following these events, the reported physician brought a lawsuit in Tulsa County District Court against the reporting doctor, asserting claims for intentional infliction of emotional distress, malicious prosecution, and tortious interference with business relations.The defendant moved to dismiss the suit under the Oklahoma Citizens Participation Act (OCPA), which provides an expedited process for dismissing lawsuits based on protected First Amendment conduct. The trial court held a hearing on the motion to dismiss and allowed limited discovery but did not rule on the motion within the statutory 30-day period. More than six years later, the trial court granted the motion to dismiss. The plaintiff appealed, arguing that the motion to dismiss was denied by operation of law when the trial court failed to rule within the required deadline. The Oklahoma Court of Civil Appeals agreed, reversing the trial court’s dismissal and remanding the case.Upon review, the Supreme Court of the State of Oklahoma held that the February 4, 2019 proceeding constituted a hearing on the motion to dismiss under the OCPA. Although the trial court permitted limited discovery, it did not extend the hearing date as allowed by statute. Therefore, the court was required to rule within 30 days, and its failure to do so meant that the motion to dismiss was denied by operation of law on March 6, 2019. The trial court lacked authority to grant the motion years later. The Supreme Court vacated the Court of Civil Appeals’ opinion, reversed the trial court’s order granting dismissal, and remanded the case for further proceedings. View "RIVERO v. STAHLHEBER" on Justia Law

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