Justia Oklahoma Supreme Court Opinion Summaries

The dispute concerns a unitized oil and gas operation in Pottawatomie County, Oklahoma. The unit, created in 1961 and amended in 2012, includes multiple wells and owners. Appellants, who own royalty interests and a working interest in a new wellbore, drilled a new well into the Bois d'Arc formation, contending it is a largely untapped reservoir not being produced by existing unit wells. After negotiations with the main operator, Americo Oil, broke down, Appellants sought to amend or terminate the unitization order and plan, arguing the discovery of this new reservoir warranted such action.The Oklahoma Corporation Commission first reviewed the application. An administrative law judge and appellate referee recommended dismissal, and the Commission adopted these recommendations. The Commission concluded that because the unitization plan contained provisions allowing amendment or termination by the operating committee, Oklahoma Administrative Code 165:5-7-20(c) limited its own authority; the Commission believed it could not terminate or amend the plan except as provided within the plan itself. As Americo Oil controlled the operating committee, Appellants were effectively denied Commission intervention.The Court of Civil Appeals of the State of Oklahoma, Division III, reviewed the Commission’s order. The court applied a de novo standard to statutory interpretation and determined that the Commission retains authority over its previously issued unitization orders, regardless of provisions in the plan for amendment or termination. The court found that the Commission's interpretation improperly restricted its statutory power to protect correlative rights and prevent waste. The main holding is that the Oklahoma Corporation Commission has continuing authority to amend or terminate unitization orders, even where the plan contains provisions for amendment or termination. The court reversed the Commission’s dismissal and remanded the case for further proceedings. View "Vertical Exploration v. Americo Oil" on Justia Law

Two homeowners brought suit against their homeowners' association and its board members, claiming improper use of dues, unlawful sale of a storage unit, failure to hold proper meetings, and allowance of illegal activities on the premises. The plaintiffs communicated concerns to the board and demanded relevant documents, but ultimately filed a lawsuit soon after sending a demand that the board bring suit against certain directors. They later amended the petition to add an additional defendant. The board had responded to some allegations, including rescinding the contested sale and scheduling meetings, but plaintiffs argued the board failed to investigate or act in good faith.The Oklahoma County District Court granted summary judgment to all defendants. The court found that plaintiffs’ affidavits lacked evidentiary support and that the brief interval between the plaintiffs’ pre-suit demand and the filing of the lawsuit did not allow the board enough time to investigate and make a good faith decision. The district court also determined that plaintiffs had failed to meet their burden of proving the board breached fiduciary duties and did not make a pre-suit demand regarding one defendant. The Court of Civil Appeals affirmed, holding that the demand requirement was not met and that the business judgment rule protected the board's decisions.The Supreme Court of the State of Oklahoma granted certiorari and reviewed the case de novo. The Court vacated the opinion of the Court of Civil Appeals but affirmed the district court’s judgment. The Court held that plaintiffs’ pre-suit demand did not provide a reasonable time for the board to investigate, as required for a shareholder derivative claim. The Court also found plaintiffs failed to rebut the business judgment rule and did not provide material facts warranting trial. Thus, summary judgment for defendants was affirmed. View "HOWARD v. THE BARRINGTON HOMEOWNERS" on Justia Law

Monica Moreno Goodwin, while employed as a mental health technician, sustained injuries to her right shoulder and neck following an incident with a patient. Her employer admitted the injuries and designated a treating physician. Goodwin subsequently amended her workers’ compensation claim to include additional body parts, notably a consequential injury to her right arm. The employer denied responsibility for the right arm injury. An Independent Medical Examiner determined the right arm injury was consequential to the original shoulder injury, leading to an order for the employer to provide medical treatment for the right arm.The employer selected a physician who diagnosed the arm injury but determined that no further treatment was necessary. Goodwin then sought enforcement of the previous order for medical treatment and requested a change of treating physician for her right arm. The Administrative Law Judge granted the change of physician, finding that the statute did not limit the number of changes per claim. The Workers’ Compensation Commission affirmed the ALJ’s ruling. However, the Oklahoma Court of Civil Appeals reversed, holding that only one change of physician per case was allowed.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on the interpretation of 85A O.S.Supp.2013 § 56(B) under the Administrative Workers’ Compensation Act. The Court held that the statute mandates the first change of treating physician but is silent regarding subsequent changes. Therefore, it does not prohibit multiple changes of treating physician per claim. The Court vacated the order of the Court of Civil Appeals and affirmed the Workers’ Compensation Commission’s decision, allowing the change of treating physician for Goodwin’s right arm. View "St. Anthony v. Goodwin" on Justia Law

The case concerns a referendum petition submitted in Norman, Oklahoma, regarding a municipal ordinance that adopted the Rock Creek Entertainment District Project Plan. The ordinance created two tax increment financing districts to support the construction of a multipurpose arena, parking garage, and related infrastructure. The increments from local sales and ad valorem taxes were designated to fund the project up to certain financial limits or for a maximum period of twenty-five years. The ordinance was enacted without voter approval, prompting proponents to submit a referendum petition seeking a public vote on the ordinance.After the petition was filed, including 10,689 signatures, a protest was lodged in the District Court of Cleveland County, challenging both the legal sufficiency and signature count of Referendum Petition 2425-1. The protest focused on alleged inaccuracies and omissions in the petition’s gist, which is intended to briefly and accurately describe the purpose and effect of the proposed measure for potential signatories. The District Court, presided over by Judge Jeff Virgin, concluded that the gist was insufficient, specifically finding that it misrepresented the financial triggers and duration of the tax districts, and ordered the petition invalidated and stricken.On appeal, the Supreme Court of the State of Oklahoma reviewed the sufficiency of the gist de novo. The Court determined that the gist failed to accurately state the maximum amount of public assistance and omitted the fact that the tax districts would expire upon the earliest of three specified events, not necessarily after twenty-five years. These deficiencies rendered the gist misleading and legally insufficient. The Supreme Court affirmed the District Court’s order invalidating Referendum Petition 2425-1, holding that the petition’s gist was legally insufficient and therefore the petition could not proceed. View "Allison v. McCoy-Post" on Justia Law

NonDoc Media and William W. Savage III submitted open records requests to the University of Oklahoma seeking two reports prepared by the law firm Jones Day. The reports resulted from investigations into allegations of misreporting alumni donor data and possible sexual misconduct involving high-ranking University officials. Jones Day was retained under an attorney-client relationship, and the reports included confidential interviews and legal analysis. Portions of the reports were provided to law enforcement under joint-interest agreements and excerpts of the sexual misconduct report were shared with the parties involved pursuant to Title IX protocols.The District Court of Cleveland County conducted an in camera review of both reports. It granted summary judgment in favor of the University, finding the documents protected by attorney-client privilege. The court also found that the reports were exempt under the Open Records Act’s personnel record exemption, and that the sexual misconduct report was further protected by work-product and informer privileges. The court did not find that the University had waived any of these protections, and rejected NonDoc’s arguments to the contrary. NonDoc appealed, and the Supreme Court of Oklahoma retained the case.The Supreme Court of the State of Oklahoma reviewed the summary judgment de novo and affirmed the district court’s decision. The Supreme Court held that the attorney-client privilege protects the reports from disclosure, and clarified that the privilege does not expire when the underlying investigation or action concludes. The court also found that the University did not waive the privilege by sharing the reports with law enforcement under joint-interest agreements or by limited disclosure required by law. Summary judgment for the University was affirmed. View "NONDOC MEDIA v. STATE Ex Rel. BOARD OF REGENTS of the UNIV. of OKLAHOMA" on Justia Law

After Oklahoma entered into a Master Settlement Agreement with the tobacco industry in 1998, the state created the Tobacco Settlement Endowment Trust Fund (TSET) through a constitutional amendment approved by voters in 2000. TSET was established to manage and disburse funds from the settlement for health-related programs, especially those targeting tobacco prevention and cessation. The TSET Board of Directors was designed to be independent, with seven members appointed by various state officials for staggered, fixed seven-year terms, ensuring geographic and political diversity and preventing control by any single authority.During the 2025 legislative session, the Oklahoma Legislature passed HB 2783, amending the statute governing the TSET Board. The new law allowed directors to serve at the pleasure of their appointing authority, subject to a maximum seven-year term, effectively converting the Board members’ tenure from fixed terms to at-will appointments. TSET challenged this amendment, claiming it violated the Oklahoma Constitution’s requirement for fixed seven-year terms.The Supreme Court of the State of Oklahoma reviewed the case in its original jurisdiction because of its statewide importance and the need for a prompt decision. The Court found the constitutional language in Article X, Section 40(D) to be clear and unambiguous, requiring staggered, fixed seven-year terms for TSET directors with no provision for at-will removal. The Court held that HB 2783 was unconstitutional because it conflicted with the constitutional mandate for fixed terms and undermined the independence of the Board. Accordingly, the Court granted declaratory relief, invalidating HB 2783. View "TOBACCO SETTLEMENT ENDOWMENT TRUST FUND v. STITT" on Justia Law

A group of Oklahoma taxpayers, parents of public school children, teachers, and clergy challenged the adoption of the 2025 Oklahoma Academic Standards for Social Studies. They argued that the new standards promoted Christianity over other religions, required teaching religious stories as historical fact, and included instructions to question the legitimacy of the 2020 Presidential Election and the origins of COVID-19. The petitioners claimed these standards violated state statutes, the Oklahoma Constitution, and their rights as parents and citizens. They further alleged that the procedure used to adopt the standards violated the Oklahoma Open Meeting Act, as the public and several Board members received the final version less than twenty-four hours before the Board meeting where the standards were approved.No lower court reviewed this case prior to the current proceeding. The petitioners brought their claims directly to the Supreme Court of the State of Oklahoma by seeking original jurisdiction, requesting declaratory, injunctive, and mandamus relief, and a stay of enforcement. The Supreme Court previously issued a temporary stay to prevent the implementation of the 2025 Standards while considering the matter.The Supreme Court of the State of Oklahoma assumed original jurisdiction due to the statewide importance and urgency of the controversy. The Court held that the 2025 Oklahoma Academic Standards for Social Studies were adopted in violation of the Oklahoma Open Meeting Act, specifically because the public and Board members did not receive proper notice of the content to be considered and acted upon. The Court determined that legislative “deemed approval” did not cure this procedural violation. As a result, the Court declared the 2025 Standards unenforceable, dissolved the earlier stay, and reinstated the 2019 standards until new standards are properly adopted and reviewed. The request for mandamus relief was withheld without prejudice. View "RANDALL v. FIELDS" on Justia Law

Melissa Evans passed away in a car accident in 2020, leaving a will that named her former spouse, Scott Evans, as the primary beneficiary and three children—Joshua (her son and appellant), Ryan (her biological son), and Tamra (her former stepdaughter)—as contingent beneficiaries. After her death, Joshua initiated probate proceedings in Rogers County District Court, seeking appointment as personal representative and determination of heirs. The petition identified only Joshua and Ryan as heirs, omitting Scott and Tamra, who were named in the will. Notice of the probate hearing was not provided to Scott or Tamra.The Rogers County District Court admitted the will to probate and issued an order in November 2020 identifying Joshua and Ryan as the sole heirs, devisees, and legatees. Joshua was appointed personal representative but was later removed, with James Greer eventually appointed as successor personal representative. In January 2024, Greer moved to vacate the portion of the 2020 order identifying heirs and beneficiaries, arguing that proper notice had not been given. The court granted the motion in March 2024. In May 2024, after a hearing with all relevant parties, the court modified the order, identifying Tamra as a beneficiary under the will, though the written order recognized Joshua and Ryan as heirs-at-law and all three as beneficiaries.The Supreme Court of the State of Oklahoma reviewed the appeal. It held that Joshua's challenge to the order vacating the prior determination of heirs was untimely, as it was not appealed within the required thirty-day period. Furthermore, the court found that the modified order determining heirs and beneficiaries was interlocutory and not immediately appealable, as it did not affect a substantial right. The appeal was dismissed, with the court noting that the determination of heirs and beneficiaries remains subject to revision until the final decree of distribution. View "IN THE MATTER OF THE ESTATE OF EVANS v. GREER" on Justia Law

The case involves a request made by an individual to the Oklahoma State Department of Health for correspondence related to the COVID-19 pandemic, specifically seeking email records sent to the Governor’s office. The requester asked for digital copies, expressing a preference for receiving the records by email. The Department produced over 11,000 pages of email correspondence in PDF format, but the requester argued that this was insufficient because the PDFs did not contain the embedded metadata present in the emails’ native file format (such as PST files from Microsoft Outlook), which he believed was necessary for fully understanding the records.After initially filing for declaratory and injunctive relief in the District Court of Oklahoma County, the Department responded by providing records in PDF format and, later, some in native format. The Department moved for summary judgment, contending that the Oklahoma Open Records Act (ORA) did not require production in native file format. The District Court agreed, granting summary judgment for the Department and finding substantial compliance with the ORA. On appeal, the Oklahoma Court of Civil Appeals reversed, holding that the Department was required to provide records in their native format if it had the capability to do so. The Department then sought review from the Oklahoma Supreme Court.The Supreme Court of the State of Oklahoma held that the ORA does not require a public body to provide copies of email records in their native file format containing embedded metadata. The Court found the statute’s language clear, interpreting “data files” not to include metadata, and concluded that the Act does not obligate agencies to provide records in any specific format, so long as reasonable access is provided. The Supreme Court vacated the Court of Civil Appeals’ opinion and affirmed the District Court’s order. View "BROOKE v. REED" on Justia Law

A bail bondsman requested records from a county jail operated by a public trust after an incident involving his ex-wife at the facility. Specifically, he sought audio and video footage, communications, jail policies and procedures, and a list of employees working during a certain time frame, citing the Oklahoma Open Records Act (ORA). The jail trust denied most of the requests, asserting that as a "law enforcement agency" under the ORA, it had discretion to withhold the records except for certain mandatory disclosures.The District Court of LeFlore County granted summary judgment to the jail trust, agreeing with its argument that it qualified as a "law enforcement agency" under the ORA. The court thus found the trust had discretion to withhold the requested records and was not required to provide them to the requester.On appeal, the Supreme Court of the State of Oklahoma reviewed the matter de novo and focused on whether the jail trust fit the statutory definition of a "law enforcement agency" under 51 O.S.2022, § 24A.3(5). The court concluded that, although the trust was a "public body," it was not "charged with enforcing state or local criminal laws and initiating criminal prosecutions" as required by the statute. The court emphasized that the trust merely operated the jail and was not responsible for enforcing laws or initiating prosecutions. As a result, the court held that the jail trust does not qualify as a "law enforcement agency" under the ORA. The Supreme Court of Oklahoma reversed the district court's summary judgment and remanded the case for further proceedings. View "LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM." on Justia Law