Justia Oklahoma Supreme Court Opinion Summaries

An Oklahoma district court ordered the admission to probate of a will executed in 2018 by Velda Mae Rivenburg, after denying challenges to the will brought by the testator's son. Velda Mae was survived by one son, Appellant Earl Austin Rivenburg (Austin), and one daughter, Appellee Bridget Ciliberti (Bridget). In April 2018, Rivenburg fell ill. Bridget traveled from her home in Tennessee to help her mother. Austin, who was stationed overseas as a civilian employee with United States Government, obtained leave from his post to travel to Oklahoma. That summer, after Austin returned to his overseas job, he was contacted by a long-time friend of Rivenburg's, Karen Heizer. Heizer was concerned that Bridget might be manipulating their mother into selling or mortgaging real estate to help Bridget pay off debt. Austin called his mother in June 2018 and broached the subject. Rivenburg became angry and hung up. Within weeks of returning to his job, Austin received notice that Bridget had initiated guardianship proceedings for their mother. The topic had never been discussed while Austin was in Oklahoma. Writing to the court, Austin objected to Bridget being appointed guardian, listed examples of what he believed to be a history of Bridget's financial manipulation of their mother. The guardianship was abandoned as soon as Rivenburg decided to change her will in September 2018. This will differed considerably from one Rivenburg had made in 2014, substantially reducing the property bequeathed to Austin in favor of Bridget. After Rivenburg's death in early 2020, Bridget sought to probate the 2018 will and have herself named personal representative. Austin challenged the will, claiming it was the product of fraud and undue influence on Bridget's part. The trial court granted demurrers to both of Austin's claims and admitted Rivenburg's 2018 will to probate. Austin appealed. The Court of Civil Appeals affirmed. The Oklahoma Supreme Court determined the Court of Civil Appeals erred by conflating the concepts of fraud and undue influence, and by treating certain facts as essentially dispositive as to both. "While the ultimate burden of persuasion remains with Austin as challenger to the will, the burden of producing evidence to rebut an inference of fraud shifted to Bridget. Accordingly, the trial court's order admitting Rivenburg's will to probate is reversed, and the case is remanded to give Bridget an opportunity to present evidence on the issue of fraud." View "Rivenburg v. Cilberti" on Justia Law

The appellants in this case filed an action to permanently enjoin enforcement of five Acts of the Oklahoma Legislature. Each Act concerned the termination of a pregnancy. The appellants' challenges were based upon Oklahoma law and not federal law. They argued there was a constitutional right to terminate a pregnancy under the Oklahoma Constitution. The trial court denied a temporary injunction on three of the Acts, which was the basis of this appeal. The Oklahoma Supreme Court granted a temporary injunction pending appeal, vacated the trial court's order denying temporary injunction, directed it to grant a temporary injunction and remanded the matter for further proceedings on the merits. View "Oklahoma Call for Reproductive Justice v. Drummond" on Justia Law

Medical providers sued insurance company to enforce their perfected medical liens for professional services rendered to a person injured in a car accident. Insurance company disputed the: (1) reasonableness of the charges; and (2) necessity of the services. The providers argued the insurance company had no legal standing to dispute these issues, absent an assignment from the injured party. Although Insurance company prepared the "Release" with the injured person, it failed to include such an assignment. Insurance company argued that in spite of this omission, there was an "implied" assignment from the injured party as evidenced by precontract settlement discussions. The trial court ruled that there was no assignment in the executed written release and that insurance company was barred by the Parol Evidence Rule from presenting evidence to establish an implied assignment. The Oklahoma Court of Civil Appeals reversed the trial court holding that summary judgment was not proper when there was a question of fact surrounding the issue of an assignment. The Oklahoma Supreme Court found there was no assignment in the executed release and there was no question of fact on material issues. Without evidence of fraud, the Court found precontract negotiations and all discussions were merged into and superseded by the terms of an executed written release. The decision of the Court of Civil Appeals was vacated; and this matter was remanded to the trial court for proceedings. View "Accident Care & Treatment Center v. CSAA General Insurance Co." on Justia Law

The parents of Elliott Williams created their individual wills and joint trust after Elliott died. A wrongful death lawsuit was filed on Elliott's behalf, and the Williamses were statutory beneficiaries to proceeds from the lawsuit. Before they received any such proceeds, they attempted to transfer them into their trust for estate planning purposes. Both parents subsequently died before the proceeds were determined or distributed. The petitioner, the personal representative of Elliott's mother's estate, then sought to have Elliott's mother's share judicially determined to belong in the trust. The trial court determined they belonged in the trust. The personal representative of the father's estate appealed, and the Court of Civil Appeals affirmed. In an issue of first impression, the Oklahoma Supreme Court considered whether proceeds from a wrongful death case could be transferred into a trust before they are obtained by the trust settlor. The Court held that they can, and if they were, they belonged in the trust. View "Hamilton v. Welsh" on Justia Law

The Church of the Servant was affiliated with the Oklahoma Annual Conference of the United Methodist Church (UMC). The Church wished to undergo the process of disaffiliation from UMC while retaining its real property, as provided in Paragraph 2553 of the United Methodist Book of Discipline. The Church ultimately sued UMC in pursuit of this goal, and the trial granted it injunctive relief. The Oklahoma Supreme Court concluded this remedy violated the doctrine of church autonomy, and the respondent court lacked subject matter jurisdiction to hear the case. View "Oklahoma Annual Conference of the United Methodist Church v. Timmons" on Justia Law

The First United Methodist Church of Oklahoma City (First Church) was affiliated with the Oklahoma Annual Conference of the United Methodist Church (UMC). First Church wished to undergo the process of disaffiliation from UMC while retaining its real property, as provided in Paragraph 2553 of the United Methodist Book of Discipline. First Church ultimately sued UMC in pursuit of this goal, and the trial granted it injunctive relief. The Oklahoma Supreme Court concluded this remedy violated the doctrine of church autonomy, and the respondent court lacked subject matter jurisdiction to hear the case. View "Oklahoma Annual Conference of the United Methodist Church v. Timmons" 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

Plaintiff Steven Bird, an independent contractor hired to install a new checkout lane at Defendant Pruett's Food store, was injured after falling off a ladder Defendant had supplied to aid Plaintiff in completing the work. Plaintiff initiated a negligence action, seeking damages from his injuries and lost wages. Plaintiff presented his case at trial, after which Defendant demurred to Plaintiff's evidence. The trial court sustained the demurrer. Plaintiff appealed. The Oklahoma Supreme Court held that Plaintiff failed to establish that Defendant owed him a duty of care. View "Bird v. Pruett's Food, Inc." on Justia Law