Justia Oklahoma Supreme Court Opinion Summaries

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

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