Justia Oklahoma Supreme Court Opinion Summaries

Kevin Cantwell worked for Flex-N-Gate for 28 years during which he sustained numerous work-related injuries. He was awarded permanent partial disability (PPD) benefits for these injuries under the law as it existed before February 1, 2014, referred to as Title 85. After this date, workers' compensation claims were governed by a new law, Title 85A, under the Administrative Workers' Compensation Act (AWCA). Cantwell sustained three more injuries after the enactment of AWCA and was again awarded PPD benefits. However, the Workers' Compensation Commission denied payment of these benefits based on their interpretation of Section 46(H) of the AWCA, which limited the total weeks of PPD benefits to 350.The Supreme Court of the State of Oklahoma, in this case, disagreed with the Commission's interpretation. The court determined that the 100% limitation on PPD benefits under Section 45(C)(1) of the AWCA controls over the number of weeks when awarding compensation for PPD. This is particularly applicable where a claimant has compensable awards for job-related injuries that occurred both before and after February 1, 2014. The court vacated the Commission's order in each case and remanded the cases for further proceedings consistent with this opinion. View "CANTWELL v. FLEX-N-GATE" on Justia Law

Plaintiffs-appellants Michael Cathey and Vonderosa Properties, LLC (collectively "Vonderosa") filed suit seeking declaratory relief against Defendant-Appellee Board of County Commissioners for McCurtain County (Board) and moved for a temporary injunction to restrain and enjoin the Board from enforcing and collecting a lodging tax increase passed at a special election held in McCurtain County on November 8, 2022, in conjunction with the general election. The district court denied Vonderosa's request for a temporary injunction and Vonderosa appealed, seeking emergency relief from the Oklahoma Supreme Court. On March 28, 2023, the Supreme Court entered an Order temporarily enjoining enforcement of the 2% increase to the lodging tax until the special election was fully and finally litigated. The Court expressed no opinion concerning the validity of the special election in its emergency Order. While Appellee's petition for rehearing was still pending before the Supreme Court and before the mandate issued, the district court granted Appellee-Intervenor's Motion for Summary Judgment and held the special election was valid. The Supreme Court held that under the facts of this specific case the district court was without jurisdiction to enter summary judgment for Appellee while the appeal was pending before the Supreme Court and before mandate had issued. The District Court's Order of June 20, 2023 was void for lack of jurisdiction and the Order was vacated. The case was remanded to the district court with instructions. View "Cathey v. McCurtain County Bd. of County Comm'rs" on Justia Law

Plaintiffs were allegedly injured from a collision with an Oklahoma Highway Patrol (OHP) Trooper. Less than three weeks after the accident, plaintiffs' lawyer sent the OHP a letter asking it to preserve any evidence relating to the incident, and to request some additional information. OHP forwarded the letter to the Oklahoma Office of Management & Enterprise Services (OMES) and OMES unilaterally determined that the request letter was the statutory notice of a governmental tort claim, triggering the time limits within the Oklahoma Governmental Tort Claims Act (the Act). Plaintiffs' lawyer disagreed. Less than one year after the accident, the lawyer sent a notice of governmental tort claim to OMES. Five months later, plaintiffs filed a lawsuit against the OHP, seeking recovery for their injuries. OHP filed a motion to dismiss, arguing that the letter requesting the preservation of evidence was notice of a governmental tort claim triggering time limits which had already expired by the time plaintiffs filed their lawsuit. The trial court agreed, and dismissed the cause. The Oklahoma Supreme Court granted review to determine whether plaintiffs' letter requesting the preservation of evidence constituted the required statutory notice of a governmental tort claim. The Court held that it did not. View "Ullman v. Oklahoma Highway Patrol" on Justia Law

Oklahoma counties were required to house state prison inmates in certain instances. In turn, Oklahoma law required the state to reimburse counties twenty-seven Dollars ($27.00) per day per state inmate for the cost of housing, unless the "actual daily cost" exceeded $27. The primary issue before the Oklahoma Supreme Court concerned the meaning of "actual daily cost" as provided in 57 O.S. 2017, § 38.2. The Court held "actual daily cost" included both consumable costs as well as those additional costs that were directly attributable to housing a DOC inmate. View "Oklahoma Dept. of Corrections v. Byrd" on Justia Law

Petitioners Debbie Leo d/b/a Miller Lake Retreat, LLC, Larinda McClellan, Louise Redman Trust, Walter Myrl Redman, and Kenneth Roberts appealed a district court's order affirming the Oklahoma Water Resources Board's (the OWRB) final order granting a permit to The City of Oklahoma City (the City) to divert stream water from the Kiamichi River in Pushmataha County, Oklahoma. The City cross-appealed the district court's order denying its motion to dismiss Petitioners' petition for judicial review for lack of subject matter jurisdiction. The City contended Petitioners' failure to name the City as a respondent in their petition for judicial review of the OWRB's order was a fatal, jurisdictional flaw under the Oklahoma Administrative Procedures Act, (OAPA). The Oklahoma Supreme Court held that 75 O.S.2011, § 318(B)(2) required that the agency (here, the OWRB) be named as a respondent in the caption of the petition for review for the district court to acquire jurisdiction to review a final agency order. However, Section 318(B)(2) of the OAPA did not require the City be named as a respondent in the petition. Therefore, the district court's order finding it had jurisdiction to review the final agency order was affirmed. The Supreme Court further held the district court properly applied the Four Points of Law in O.A.C. § 785:20-5-4, including using the OWRB's calculation of available stream water and evaluation of beneficial use, which was based on substantial evidence in the record, with no findings of prejudicial error. Therefore, the district court's order affirming the OWRB's order was affirmed. View "Leo v. Oklahoma Water Resources Board" on Justia Law

The Oklahoma Turnpike Authority (OTA) brought an original proceeding to the Oklahoma Supreme Court asking the Court approve revenue bonds to finance the construction of three turnpike projects, update and repair turnpike facilities and infrastructure, refund prior revenue bonds and notes, and pay other costs. Protestants challenged the proposed bonds on several grounds, arguing that the Oklahoma Turnpike Authority lacked legislative authority to construct the three turnpikes. Title 69 O.S.2021, § 1718 provided that if the Court was satisfied that the bonds have been properly authorized in accordance with Article 17 of the Oklahoma Highway Code of 1968, 69 O.S.2021, § 1701 et seq., the Court would render its written opinion approving the revenue bonds. The OTA properly exercised its authority to determine the route for the South Extension. Further, the OTA has legislative authority pursuant to 69 O.S.2021, §§ 1705(f) and 1709(A) to issue additional bonds to finalize the Loop. Accordingly, the Supreme Court approved the revenue bonds. View "In the Matter of the Application of the Oklahoma Turnpike Authority" on Justia Law

TOCH, LLC, the owner and operator of Aloft Hotel, alleged that the Tulsa Tourism Improvement District No. 1 was allegedly improperly created because fifty percent or more of the affected hotel owners protested in writing prior to its creation. City of Tulsa and Tulsa Hotel Partners sought summary judgment on this issue and disputed this material fact by submitting affidavits to disprove TOCH's allegation. The trial court granted summary judgment to the City, but the Oklahoma Supreme Court found the trial court erred when it made a factual determination on this controverted fact. "Weighing disputed evidence is not proper on summary judgment." The trial court's decision was therefore reversed. View "TOCH, LLC v. City of Tulsa, et al." on Justia Law

Petitioners filed this original proceeding objecting to two pieces of legislation passed by the Oklahoma legislature during the 2022 legislative session: S.B. 1503 and H.B. 4327. Both acts prohibited abortion after certain cutoff points while providing for a civil enforcement mechanism; both acts prohibited enforcement by the State, its subdivisions, and its agents--instead, the bills created a cause-of-action maintainable by any person for performing, or aiding and abetting the performance of, an abortion in violation of the acts. Petitioners challenged the bills on many grounds, but the Oklahoma Supreme Court did not address them here. The Court held both bills were unconstitutional; the Court found it unnecessary to address the Petitioners' request for injunctive relief and/or writ of prohibition or Respondents' claims that Petitioners did not have a justiciable claim against them. Petitioners' request for injunctive relief and/or a writ of prohibition was denied. View "Oklahoma Call for Reproductive Justice v. Oklahoma" on Justia Law

A group of Oklahoma landowners petitioned for a declaratory judgment and injunctive relief, claiming that the Oklahoma Turnpike Authority violated the Open Meeting Act, 25 O.S.2021, §§ 301 to 314, regarding its notice to the public of the ACCESS Oklahoma Program. Both parties sought summary judgment. The district court rendered summary judgment in the landowners' favor, finding that the Oklahoma Turnpike Authority willfully violated the Open Meeting Act. The Oklahoma Supreme Court held that the Oklahoma Turnpike Authority gave sufficient notice of the agenda items that the landowners challenged. Furthermore, the Court found that the lack of notice regarding the announcement of the ACCESS Oklahoma Program at the February 2022 meeting did not violate the Open Meeting Act because the announcement was for informational purposes only. View "Hirschfeld, et al. v. Oklahoma Turnpike Authority" on Justia Law

Appellants Pike Off OTA, Inc., Amy Cerato, Mike Leary, Vince Dougherty, Terrie Club, Mike Club, Twyla Smith, Cali Coward, Karen Powell, Mike Powell, Cedric Leblanc, Darla Leblanc, Claudette Wispe, Mark Dooling, Nate Piel, Kara Piel, Nikki Whitson, John Whitson, Robert Wallace, Chelsea Wallace, Robin Stead, Anna Olson, Tassie Hirschfeld, Ice Blast LLC, and Janette Ward (collectively Appellants) brought claims challenging the Oklahoma Turnpike Authority's (OTA) authority to construct three proposed turnpikes: the Tri-City Connector, the East-West Connector, and the South Extension. The OTA moved to dismiss these claims, arguing that Appellants' claims were within the exclusive original jurisdiction of the Oklahoma Supreme Court. The district court granted the OTA's motion to dismiss, and Appellants appealed. The Supreme Court concurred it had exclusive original jurisdiction to determine whether the Oklahoma Turnpike Authority is authorized to construct the proposed turnpikes in the bond validation matter. The Court further ruled that appellants failed to establish that they had a clear legal right to the injunctive and/or mandamus relief sought. View "Pike Off OTA v. Okla. Turnpike Auth." on Justia Law