Justia Oklahoma Supreme Court Opinion Summaries

The Supreme Court of the United States certified two questions of Oklahoma law to the Oklahoma Supreme Court. The questions centered on whether H.B. No. 1970, Section 1, Chapter 216, O.S.L. 2011 prohibited: (1) the use of misoprostol to induce abortions, including the use of misoprostol in conjunction with mifepristone according to a protocol approved by the Food and Drug Administration; and (2) the use of methotrexate to treat ectopic pregnancies. The Oklahoma Court answered both questions in the affirmative. View "Cline v. Oklahoma Coalition for Reproductive Justice" on Justia Law

Plaintiff-Appellant Mastercraft Floor Covering, filed a lawsuit against Charlotte Flooring (CFI), a North Carolina corporation, in Oklahoma. Mastercraft alleged that CFI had hired it to install carpet in a North Carolina casino, but that after the work was completed, CFI failed to pay for the labor, services, and materials. CFI entered a special entry of appearance to object to Oklahoma having jurisdiction to decide the cause because CFI lacked the requisite minimum contacts to be sued in the State of Oklahoma. The trial judge, determined that Mastercraft failed to prove that CFI had sufficient minimum contacts to permit Oklahoma to exercise jurisdiction over CFI without offending conventional notions of fair play and substantial justice. Mastercraft appealed, and the Court of Civil Appeals affirmed. Upon review, the Supreme Court concluded that because of the totality of contacts with the Oklahoma-based corporation, the trial court had personal jurisdiction. View "Mastercraft Floor Covering, Inc. v. Charlotte Flooring, Inc." on Justia Law

An Oklahoma worker was killed at Employer's jobsite in Texas. The employer's insurer paid the worker's Widow death benefits provided by Texas workers' compensation law. The widow also recovered damages in a wrongful death tort action in Texas. When the Insurer sought subrogation from the widow's wrongful death damages as allowed by Texas law, she filed suit in Oklahoma to prevent subrogation. She sought a declaratory judgment that the rights of Oklahoma workers and their dependents were governed by Oklahoma's Workers' Compensation Act, notwithstanding the worker's injury or death in another state, and any benefits that may be paid under another state's workers' compensation law. In particular, Widow asked the Oklahoma court to enforce the provision in Oklahoma law that forbids subrogation in cases of death benefits. The trial court granted the declaratory relief sought by the widow. On appeal by the Insurer, the Court of Civil Appeals reversed. The Court of Civil Appeals ruled that the widow had to commence a proceeding by filing a claim with Oklahoma's Workers' Compensation Court before Oklahoma could exercise jurisdiction over the benefits due the widow, including enforcement of the anti-subrogation provision in death benefit cases. Because she never filed a claim with Oklahoma's Workers' Compensation Court, the Court of Civil Appeals held subrogation was proper. Upon review, the Supreme Court affirmed the trial court's judgment and vacated the appellate court in this case. View "Holley v. ACE American Ins. Co." on Justia Law

The issue presented to the Supreme Court in this case was whether the district court erred in proceeding in the underlying foreclosure suit after the defendant filed a motion giving notice of the plaintiff corporation's suspension in June of 2000 for failure to pay corporate franchise taxes; for the eleven months that the plaintiff was on notice that its suspension was an issue in the suit, the corporation failed to be reinstated; and title 68, section 1212(C) of the Oklahoma Statutes denies a suspended corporation the right to sue or defend. Upon careful consideration, the Supreme Court held that the district court did err in proceeding; the Court therefore issued a writ of mandamus to direct the district court to vacate all orders previously entered. View "Moncrieff-Yeates v. Kane" on Justia Law

Appellant filed a Motion to Override Risk Level Classification under the Sex Offenders Registration Act (SORA). The trial court ruled it did not have jurisdiction to grant the relief requested. The trial court record did not reflect when appellant was first required to register, but he began actual registration in the summer of 2007. Following appellant's initial registration, the State of Oklahoma ex rel. Oklahoma Department of Corrections, notified appellant that he had been assigned a numeric risk level of three and would thereafter have to register for life. Appellant claimed that prior to this determination of a level assignment he was only required to register for ten years. Appellant filed a Motion to Override Risk Level Classification and Brief in Support in 2009. Less than two weeks after appellant filed his motion, new amendments to SORA took effect. In light of the amendments, the trial court ruled it lacked jurisdiction to grant appellant relief. Upon review, the Supreme Court concluded that the Department could not retroactively increase his registration period. As such the trial court had jurisdiction over appellant's case. The matter was reversed and remanded for further proceedings. View "Burk v. Oklahoma" on Justia Law

Plaintiff Joseph W. Hendricks challenged the constitutionality of the Sex Offenders Registration Act ("SORA") and its enforcement. Upon review, the Supreme Court held that applying SORA's requirements to sex offenders now residing in Oklahoma who were convicted in another jurisdiction prior to SORA's enactment but not applying the same requirements to a person convicted in Oklahoma of a similar offense prior to SORA's enactment, violates a person's equal protection guarantees. View "Hendricks v. Jones" on Justia Law

Plaintiff Michael Bollin challenged the constitutionality of the Sex Offenders Registration Act (SORA) and its enforcement. Upon review, the Supreme Court found that when Bollin entered Oklahoma in June 2004, the law did not require a person with a pre-SORA conviction in another jurisdiction to register. Therefore, Bollin should have been held to the law in effect at the time he entered Oklahoma and became subject to SORA. Therefore, Bollin was not required to register under SORA. View "Bollin v. Jones" on Justia Law

In 2009, respondent Adrian Melton suffered an on-the-job accident while working for his employer, Joe Brown Company, Inc. He was awarded eleven weeks of temporary total disability, granted permanent partial disability, and a psychological overlay. The employer appealed the award, which vacated some parts and sustained others. In 2011, the employer appealed to the Court of Civil Appeals (COCA) which vacated the permanent partial impairment award because it failed to comply with the AMA Guides (5th Edition), and that an "any competent evidence" standard of review was inconsistent with 85 O.S. 2011 sec. 340, so the court used the "against the clear weight of the evidence" standard which had recently been revised. Respondent petitioned the Supreme Court for review of the COCA decision, arguing that the appellate court should have used the "any competent evidence" standard. Upon review of the matter, the Supreme Court concluded that because respondent's injury happened before the new standard went into effect, the "any competent evidence" standard should have been applied. With regard to respondent's awards of disability, the Court found that psychological overlay was not supported by appropriate expert testimony. Accordingly, the benefits as they related to the overlay were vacated. View "Joe Brown Company, Inc. v. Melton" on Justia Law

Petitioner Sedrick Courtney filed for post-conviction relief based on exonerating DNA evidence. He asked the district court to vacate his robbery conviction and to determine his actual innocence for the robbery in order to pursue a claim for wrongful conviction. The court vacated the conviction but declined to determine actual innocence. Petitioner appealed this denial with the Court of Appeals and the Supreme Court (unsure which court to choose). The Supreme Court assumed original jurisdiction over the case (because review of requests to determine actual innocence fall within the Court's original jurisdiction). Upon review of the case, the Supreme Court concluded the trial court erred in denying petitioner's request for a threshold determination of actual innocence following the vacation of his criminal conviction in a post-conviction relief proceeding. Specifically, the Court held that the trial court erred in (1) ruling that petitioner had not presented clear and convincing evidence of his actual innocence in the face of the exonerating DNA evidence that supported the vacation of the conviction, and (2) dismissing petitioner's request to determine actual innocence without prejudice to pursuing such relief in a court of general jurisdiction. View "Courtney v. Oklahoma" on Justia Law

Appellants are a licensed bail bondsman and several insurance companies that issue bail bonds. They filed a complaint against defendant registered professional bail bondsman Curt Pletcher violated the Ten Bond Rule of the Oklahoma Bail Bondsmen Act by using a surety bondsman to write more than ten bonds per year in Oklahoma County. Pletcher filed a motion to dismiss on the ground that the petition failed to state a claim because the Ten Bond Rule was held to be unconstitutional by the Sequoyah County district court. The district court judge enjoined the Insurance Commissioner from enforcing the Ten Bond Rule. Appellants argued that the Sequoyah County case was not binding on the Oklahoma County District Court because it did not involve any of the same parties and the decision was not appealed. The trial judge denied Pletcher's motion to dismiss. The trial court recognized that it was in the public interest to get the matter straightened out, but he did not believe that an injunction was the way to do so. He directed the parties to brief the constitutionality of the statute, the effect of the judge's ruling and whether the Insurance Commissioner was a necessary party. He advised the parties that in order to consider constitutionality he wanted a record made for the Supreme Court's review. Upon review, the Supreme Court found that the trial judge did not abuse his discretion in denying a temporary injunction to enforce the statute. View "Dowell v. Pletcher" on Justia Law