Justia Oklahoma Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Plaintiff-Appellee Christopher Luster filed a Petition for Temporary and Permanent Injunction, Temporary Restraining Order, and Declaratory Relief to enjoin the State of Oklahoma ex rel., Department of Corrections, from enforcing the Sex Offenders Registration Act against him. The trial court consolidated this case with those of other plaintiffs filing similar actions and granted a permanent injunction to all the consolidated plaintiffs. On appeal the Department asserted the Legislature's intent was clear in applying the provisions of SORA retroactively. For the same reasons the Oklahoma Supreme Court held the provisions of SORA in effect upon a person being convicted in Oklahoma or entering Oklahoma were the only SORA provisions that should apply to the sex offender, the Court held the frequency of SORA verification in effect at that time was also the applicable provision. The correct registration requirements to apply are those in effect when the sex offender was either convicted in Oklahoma or when a sex offender convicted in another jurisdiction enters Oklahoma and becomes subject to those registration requirements. Therefore, the Court reversed the trial court's Order applying a blanket one-year registration frequency to the consolidated plaintiffs who must continue registering. View "Luster v. Oklahoma ex rel Dept. of Corrections" on Justia Law

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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

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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

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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

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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

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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

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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

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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

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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

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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