Justia Oklahoma Supreme Court Opinion Summaries

In 2014, Petitioner Theresa Maxwell suffered an injury to her knee while working for her Employer, Respondent Sprint PCS. She promptly notified her Employer and timely filed a CC-Form-3 with the Workers' Compensation Commission. The Employer admitted Petitioner's injury to her knee was compensable, and she had surgery to repair a tendon in her knee. Petitioner also received temporary total disability benefits from February 6, 2014, until February 24, 2014. After reaching maximum medical improvement on July 2, 2014, she returned to her pre-injury position with her employer earning her pre-injury wages. Later that year, Petitioner filed a request for a contested hearing on the issue of permanent partial disability. The ALJ concluded that Petitioner sustained 2% permanent partial disability to the body as a whole as a result of the injury to her knee and that the rate of compensation was $323.00 for a total award of $2,261.00. However, because she returned to her pre-injury position and pay, the ALJ ordered the award of benefits be deferred at a rate of $323.00 beginning July 2, 2014, for every week Petitioner worked in her pre-injury or equivalent job. Petitioner appealed the order, and the Workers' Compensation Commission sitting en banc affirmed. The Supreme Court concluded that scheduled members are exempt from the AMA Guides under the AWCA. The Court also held that the permanent partial disability deferral provision of 85A O.S. Supp. 2013 sec. 45(C)(5) was an unconstitutional violation of due process under Art. 2, section 7.51 Sections 45(C)(5)(a-e) were invalid and stricken. The deferral of permanent partial disability benefits to a subclass of injured workers under 85A O.S. Supp. 2013 sec. 46(C) was an unconstitutional special law under Art. 5, sec. 59.52. Only that portion of Section 46(C) that made the deferral provision applicable to injuries to the body as a whole or "other cases" was invalid. Any definitional provisions found in 85A O.S. Supp. 2013 section 2, as were deemed invalid to the extent they were inconsistent with the Court's opinion with regard to this matter. On remand, the Commission, through its ALJs, were mandated to take all action necessary to implement the pronouncement made by this case. View "Maxwell v. Sprint PCS" on Justia Law

Plaintiff-appellant and Oklahoma taxpayer Robert Dani claimed certain property, which had previously been handed over to the State Treasurer pursuant to the Uniform Unclaimed Property Act (UUPA), because it was presumed abandoned. This property consisted of $19.56, received in 2004 and submitted by Chevron/Texaco, as well as $150.00, received in 2013 and submitted by Office Depot, Inc. Appellant filed a claim for this property on or about January 16, 2014. His claim was approved, and a check was issued to Appellant for $169.56 on April 17, 2014. On June 22, 2015, Appellant filed suit against the State, seeking damages, declaratory relief, and injunctive relief, concerning the constitutionality and administration of the UUPA. He also alleged the UUPA was a "Ponzi scheme," again focusing on the constitutionality of the UUPA. The case was dismissed for failure to state a claim upon which relief could be granted, and Appellant appealed. Finding no reversible error, the Supreme Court affirmed. View "Dani v. Miller" on Justia Law

Plaintiff-appellant and Oklahoma taxpayer Robert Dani claimed certain property, which had previously been handed over to the State Treasurer pursuant to the Uniform Unclaimed Property Act (UUPA), because it was presumed abandoned. This property consisted of $19.56, received in 2004 and submitted by Chevron/Texaco, as well as $150.00, received in 2013 and submitted by Office Depot, Inc. Appellant filed a claim for this property on or about January 16, 2014. His claim was approved, and a check was issued to Appellant for $169.56 on April 17, 2014. On June 22, 2015, Appellant filed suit against the State, seeking damages, declaratory relief, and injunctive relief, concerning the constitutionality and administration of the UUPA. He also alleged the UUPA was a "Ponzi scheme," again focusing on the constitutionality of the UUPA. The case was dismissed for failure to state a claim upon which relief could be granted, and Appellant appealed. Finding no reversible error, the Supreme Court affirmed. View "Dani v. Miller" on Justia Law

Plaintiff Michael Reynolds sued the Defendants-appellees, Mary Fallin, Governor of the State of Oklahoma; Ken Miller, Treasurer of the State of Oklahoma; Preston Doerflinger, State Director of the Office of Management and Enterprise Services and various unnamed state attorneys for their alleged involvement with the three general appropriation bills. The state moved to dismiss the case which was later granted by the district court. Reynolds' principle argument on appeal was that three types of sections in the challenged general appropriation bills were substantive laws and did not constitute appropriations and were as a result, unconstitutional. Reynolds challenged the "TRANSFER" sections of the general appropriation bills that transferred money from one fund to the Special Cash Fund of the State Treasury. He also challenged sections of the three general appropriation bills that provided authorization to transfer money from one fund to another and those that provide authorization to expend money. Having found no merit as to any of Reynolds' assertions of unconstitutionality, the Oklahoma Supreme Court affirmed the district court's granting of Appellees' motion to dismiss. View "Reynolds v. Fallin" on Justia Law

In 2011, the Oklahoma Legislature enacted H.B. 1970, prohibiting the off-label use of Mifeprex (generally known as "mifepristone" or "RU-486") and misoprostol (brand name Cytotec) for use in abortions. The effect of H.B. 1970 was to ban medication abortions in Oklahoma. In the first pronouncement ("Cline I"), the Oklahoma Supreme Court, following "Planned Parenthood of Southeastern Pennsylvania v. Casey," (505 U.S. 833 (1992)), affirmed the district court's decision that H.B. 1970 was unconstitutional. Appellees then filed a petition for certiorari in the United States Supreme Court. The U.S. Supreme Court granted the petition and certified two questions to the Oklahoma Supreme Court: whether H.B. 1970 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." In "Cline II," the Oklahoma Court answered both questions affirmatively. The U.S. Supreme Court then dismissed the petition for certiorari as improvidently granted. In 2014, in response to the Cline II decision, the Oklahoma Legislature passed H.B. 2684, amending Title 63, Section 1-729a of the Oklahoma Statutes. H.B. 2684 was approved by the Governor and became effective on November 1, 2014. The Bill restricted Mifeprex and misoprostol use for abortions to the FDA-approved final Mifeprex label, prohibits methotrexate use for abortions except to terminate ectopic pregnancies, provides for liability of physicians who knowingly or recklessly perform an abortion in violation of H.B. 2684, and makes doctors subject to discipline and liability for violating H.B. 2684. Plaintiffs the Oklahoma Coalition for Reproductive Justice and Nova Health Systems filed this challenge to H.B. 2684's restriction of off-label use of Mifeprex in the district court against the Oklahoma Commissioner of Health and the Executive Director of the Oklahoma State Board of Medical Licensure and Supervision (State). While this case was pending before the district court, the Oklahoma Supreme Court enjoined enforcement of H.B. 2684 until its constitutionality "is fully and finally litigated." The dispositive question presented was whether H.B. 2684, violated either of two sections of the Oklahoma Constitution: Article V, Section I or Article V, Section 59. The Court answered in the negative. View "Oklahoma Coalition for Reproductive Juctice v. Cline" on Justia Law

Several Oklahoma taxpayers filed a declaratory judgment action seeking a permanent injunction against Defendants, Joy Hofmeister, the State Superintendent of Public Instruction, the Oklahoma State Department of Education; and the Oklahoma State Board of Education, (the "State") to enjoin the payment of tuition to private sectarian schools alleging the "Lindsey Nicole Henry Scholarships for Students with Disabilities Act" (or "Scholarship Program") violated several articles of the Oklahoma Constitution. Both parties filed for summary judgment. The trial court granted in part and denied in part the parties' motions, finding the Act was constitutional on all challenged grounds except for one. The trial court entered a narrow Order ruling the Act violated the Oklahoma Constitution, Article II, Section 5, only to the extent it authorized public funds to pay the cost for students to attend private sectarian schools. This provision of the Constitution has been referred to as the "no aid" clause, prohibiting public money from being used for the benefit or support of religion. An injunction was issued to prevent payment to private religious schools, with no impact on the payment to private non-sectarian schools. The State appealed, arguing: (1) the payment to a sectarian school was permitted because it was for a valid public purpose and in exchange for consideration; and (2) the district court's construction of the Act created a religiosity distinction violating the U.S. Constitution's freedom of religion clause. After review, the Oklahoma Supreme Court reversed the district court's decision in part and found the Act did not violate the "no aid" clause. The Court did not reach defendants' second issue, and remanded this case for further proceedings. View "Oliver v. Hofmeister" on Justia Law

The issue this case presented for the Oklahoma Supreme Court's review centered on a dispute between Defendants-Appellants The Board of County Commissioners of Canadian County and certain citizens and officers of Canadian County, over the legal usage of funds generated from a sales tax enacted by the voters of Canadian County in 1996. In response to concerns raised over the legality of using funds generated by the Tax to pay for juvenile programs and services, in addition to the physical structures, an Attorney General Opinion was requested. The Attorney General issued an opinion concerning the matter in 2014. The Attorney General examined the resolution in question, Resolution No. 96-20, and determined that the language did not authorize use of the Tax for the funding of programs, salaries and expenses related to operation of the juvenile bureau, or even certain aspects of the physical facilities. In the wake of the Opinion, the Board ceased using the Tax for funding the programs, services, and salaries deemed outside the purpose of the Tax, and instead sought other funding sources for those items. Plaintiffs filed suit against the Board in the District Court in late 2014, seeking declaratory relief, a temporary restraining order and temporary injunction pending a declaratory ruling, and a writ of mandamus by way of ancillary relief. In an order filed on January 28, 2015, the trial court granted Citizens' request for a temporary injunction, determining: (1) Citizens were likely to prevail in their request for a declaratory judgment; (2) the Board would not suffer irreparable harm if the temporary injunction was issued; and (3) Citizens would suffer irreparable harm if the temporary injunction was not issued. The Board appealed, arguing that Plaintiffs failed to meet their burden of proof for a temporary injunction. After examining the available evidence, the Supreme Court determined that that the trial court's issuance of a temporary injunction was not an abuse of discretion or against the clear weight of the evidence. Accordingly, the order of the trial court granting a temporary injunction was affirmed. View "Edwards v. Bd. of Cty. Commr's." on Justia Law

Petitioner Rodney Dutton sought an extraordinary writ at the Oklahoma Supreme Court to challenge his convictions in three criminal proceedings in the municipal court for The City of Midwest City. He also requested an alternative remedy that would compel the District Court to provide him with a new appeal of his convictions in the District Court. Dutton alleged that in 2013, he was convicted in the municipal court of the City of Midwest City on charges of assault, public intoxication, and domestic assault and battery, for which he received a thirty-day jail sentence. He stated that he filed three applications for post-conviction relief at the District Court after his release. The District Court dismissed the applications on grounds that they should have been filed with the municipal court in Midwest City. His application for the Supreme Court to assume original jurisdiction was filed approximately one year and three months after his release. Dutton's claims, construed liberally because of his pro se status, alleged numerous constitutional violations and procedural errors at the municipal and district courts that entitled him to the relief he sought. The Supreme Court assumed original jurisdiction for the sole purpose of determining its jurisdiction to review Petitioner's allegations. After review, the Court held that it did not possess jurisdiction to either review the merits of Petitioner's cause of action challenging his municipal criminal convictions or compel the District Court to provide him with a new direct appeal of those convictions to the District Court. Dutton failed to show that he lacked adequate remedies in either a municipal court or the District Court. Dutton's claims were criminal matters and the Supreme Court declined to assume original jurisdiction on his claims or grant him relief on them without prejudice to him presenting them, in the proper court. View "Dutton v. City of Midwest City" on Justia Law

The question presented on appeal to the Oklahoma Supreme Court in this case was whether an owner of real property received constitutionally sufficient notice of the sale of his property for delinquent taxes when notice was provided only by publication and certified mail that was returned undelivered. Appellant-landowner neglected to pay taxes on certain real property in McIntosh County. The property was sold at a tax sale and a tax deed was issued to the buyer. The landowner filed suit seeking to invalidate the tax deed and quiet title in himself, asserting that the sale and resultant deed were void because he was not given constitutionally sufficient notice of the sale and was denied his right to redeem the property. Both the landowner and the county defendants moved for summary judgment. The trial court granted the county defendants' motion and denied the landowners. The landowner appealed, and the Court of Civil Appeals affirmed. After review, the Supreme Court held: (1) that the landowner did not receive constitutionally sufficient notice; and (2) the sale and resultant tax deed were therefore void. View "Crownover v. Keel" on Justia Law

Taxpayers Don and Mary Frankenberg made improvements to their home in 2001. The Garvin County Assessor did not increase the fair cash value of the property for the improvements until 2012 when she visually inspected the property and discovered the improvements. The Assessor notified the Taxpayers of a new assessed fair cash value, which was a substantial increase from the previous valuation in 1999. The Taxpayers protested the assessment, arguing that under Art. X, section 8B of the Oklahoma Constitution, the fair cash value of the property could not be increased more than 5% in any year. The district court granted summary judgment in favor of the Taxpayers, and the Assessor appealed. Upon review, the Supreme Court found the exception to the 5% cap for improvements to a property existed only for the year the improvements were made to the property and did not apply in the year when the Assessor first discovers the improvements. Accordingly, the Court affirmed. View "Frankenberg v. Strickland" on Justia Law