Justia Oklahoma Supreme Court Opinion Summaries

A dispute arose when Oklahoma Gas and Electric (OG&E) began providing retail electric service to a large cryogenic natural gas facility, the Chisolm Trail Plant, located in the certified territory of Oklahoma Electric Cooperative (OEC) in rural Grady County, Oklahoma. Under the Retail Energy Supplier Certified Territory Act (RESCTA), OEC holds exclusive rights to serve customers in this area, unless an exception applies. OG&E relied on the "Large Load" exception, which allows another supplier to serve a facility with an initial load of 1,000 kilowatts or more. To serve the Plant, OG&E connected to a third-party transmission line owned by Public Service Company of Oklahoma, rather than extending its own distribution system.After OG&E began service in May 2018, OEC filed an application with the Oklahoma Corporation Commission in August 2019, seeking to enjoin OG&E from serving the Plant, arguing that OG&E’s conduct violated RESCTA. The Commission, however, denied OEC’s request for injunctive relief, not by analyzing the statutory exception, but by finding that OEC’s claim was barred by the equitable defenses of laches, estoppel, and waiver, due to OEC’s delay in objecting and OG&E’s substantial investment in infrastructure.The Supreme Court of the State of Oklahoma reviewed the case and held that, under its recent decision in Oklahoma Gas & Electric Co. v. Oklahoma Corp. Comm’n (People’s), RESCTA’s Large Load exception does not permit a supplier to connect with third-party transmission lines to extend service into another supplier’s certified territory. However, because the holding in People’s applies only prospectively and not to existing service arrangements, OG&E is permitted to continue serving the Plant. The Supreme Court affirmed the Commission’s order allowing OG&E to continue providing retail electric service to the customer in OEC’s territory. View "OKLAHOMA ELECTRIC COOPERATIVE v. STATE ex rel. OKLAHOMA CORPORATION COMMISSION" on Justia Law

A former employee brought suit against her previous employer, alleging that she was terminated due to her mental and physical disabilities. The plaintiff had a history of cancer and mental health issues, and she was on short-term disability leave at the time of her termination. She claimed that her employer’s actions during her leave, including communications from supervisors and the circumstances of her termination, caused her severe emotional distress. The only claim she asserted was for intentional infliction of emotional distress, and she did not pursue any statutory discrimination claims.In the District Court of Cleveland County, the employer moved for summary judgment, arguing that the plaintiff’s claim was preempted by the Oklahoma Anti-Discrimination Act (OADA), which provides the exclusive remedy for employment discrimination claims. The trial judge initially granted summary judgment in favor of the employer, finding both that the plaintiff failed to show legally sufficient emotional distress and that her claim was preempted by the OADA. After the case was reassigned to a new judge, the plaintiff’s motion to vacate the summary judgment was granted, and the summary judgment order was set aside. The employer appealed this order.The Supreme Court of the State of Oklahoma reviewed the case and held that the OADA, as amended in 2011, provides the exclusive remedy for employment discrimination claims, preempting common law tort claims such as intentional infliction of emotional distress when they arise from the same facts as a discrimination claim. The Court found that the plaintiff’s claim was entirely based on alleged discriminatory conduct covered by the OADA and did not allege any independent, highly personal tortious conduct. The Supreme Court reversed the order vacating summary judgment and remanded with instructions to reinstate summary judgment in favor of the employer. View "Baughman v. World Acceptance Corp." on Justia Law

A group of proponents filed an initiative petition seeking to repeal the existing constitutional provision governing Oklahoma’s primary elections and replace it with a new system. The proposed amendment would establish an “open primary” for certain state and federal offices, where all candidates appear on the same ballot regardless of party, and any qualified voter may vote for any candidate. The two candidates with the most votes would advance to the general election, regardless of party affiliation or endorsement. The ballot would display each candidate’s party registration or independent status, with a disclaimer clarifying that such registration does not imply party nomination or endorsement. The measure would not affect elections for presidential electors, municipal, judicial, or school board offices.After the petition was filed with the Secretary of State, the Oklahoma Republican Party and another petitioner protested its legal sufficiency before the Supreme Court of the State of Oklahoma. They argued that the initiative was facially unconstitutional under the First Amendment, claiming it infringed on the right of political association and failed strict scrutiny. They also asserted that the gist and ballot title were misleading, particularly in their use of the term “open primary” and in the explanation of changes to general elections.The Supreme Court of the State of Oklahoma reviewed the petition. Applying its standard of review, the court found no clear or manifest facial constitutional infirmity, holding that the proposed system did not impose a severe burden on associational rights under relevant U.S. Supreme Court precedents. The court determined that the gist was not misleading, as it adequately described the practical effect of the measure. The challenge to the ballot title was deemed premature, as statutory procedure requires such review after the signature-gathering phase. The court held that the initiative petition was legally sufficient for circulation and signature gathering. View "IN RE INITIATIVE PETITION NO. 448, STATE QUESTION NO. 836: THE OKLAHOMA REPUBLICAN PARTY v. SETTER" on Justia Law

The Governor of Oklahoma issued an executive order requiring all full-time employees of state agencies to return to in-person work, with limited exceptions. A member of the Oklahoma House of Representatives challenged this order, arguing that it improperly created new law and usurped legislative authority. The legislator sought a declaratory judgment to invalidate the order and an injunction to prevent its enforcement, claiming the order encroached on the legislature’s exclusive authority over personnel policy.The case was first heard in the District Court of Oklahoma County. The Governor moved to dismiss, arguing that the legislator lacked standing because he did not suffer a direct, concrete injury from the executive order, which applied only to executive branch employees and not to legislators or their staff. The district court agreed, finding that the legislator failed to establish a sufficient personal stake or injury in fact, and dismissed the case.On appeal, the Supreme Court of the State of Oklahoma reviewed the district court’s dismissal de novo. The Supreme Court held that the legislator did not meet the threshold requirements for standing, as he was not directly affected by the executive order, nor did the order impact his legislative votes or participation. The Court distinguished this case from prior precedent where a legislator’s vote was directly at issue. The Supreme Court concluded that the legislator failed to demonstrate an actual, concrete injury and that the executive order did not usurp legislative power. Therefore, the Supreme Court affirmed the district court’s dismissal, holding that the legislator lacked standing to challenge the executive order. View "Fugate v. Stitt" on Justia Law

An employee alleged a work-related knee injury and filed a timely claim for workers’ compensation benefits, including a request for a hearing. The employer denied the claim, asserting the injury was not work-related. After an independent medical evaluation found the knee pain was due to a preexisting condition, no further medical treatment was sought or provided through the workers’ compensation system for over nine months. The employer then moved to dismiss the claim, arguing that the employee had failed to receive or seek benefits for a period exceeding six months, as required by Oklahoma law.An Administrative Law Judge denied the employer’s motion to dismiss, relying on precedent from the Oklahoma Court of Civil Appeals, and held that because the employee had requested a hearing within six months of filing the claim, dismissal was not warranted. The Workers’ Compensation Commission affirmed this decision, agreeing that the employee’s timely request for a hearing satisfied the statutory requirements and that further inquiry into whether benefits were sought or received was unnecessary.The Supreme Court of the State of Oklahoma reviewed the case and reversed the Commission’s order. The Court held that under 85A O.S. § 69(A)(4), an employee must not only make a timely request for a hearing but must also continue to actively pursue the claim by receiving or seeking benefits for any six-month period during the life of the claim. The Court found that the employee’s failure to seek or receive benefits for more than six months triggered the employer’s right to dismissal. The Court also held that the statute is constitutional, as it applies equally to all injured employees and does not violate due process or constitute a special law. The Commission’s order was vacated and the employer’s motion to dismiss was granted. View "OBI HOLDING COMPANY v. SCHULTZ-BUTZBACH" on Justia Law

Fred Hodara filed a lawsuit against the Oklahoma Department of Corrections (DOC) for alleged violations of the Open Records Act, seeking access to records related to the drugs used in executions. Initially, the DOC claimed it had no responsive records, but later provided some documents, albeit heavily redacted. Hodara sought declaratory and injunctive relief, arguing that the DOC's refusal to provide the requested material was unlawful. The DOC moved to dismiss the case, citing a statutory exemption under Title 22, Section 1015(B), which was later amended in 2024 to broaden the scope of confidentiality.The district court denied both parties' motions for summary judgment due to unresolved factual disputes. However, after the statutory amendment, the DOC filed a second motion to dismiss, which the court granted, concluding that the amended statute precluded Hodara's Open Records Act claim. Hodara appealed the dismissal, challenging the retroactive application and constitutionality of the amended statute.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on the October 4, 2024, order. The court found that the 2024 amendment to Section 1015(B) did not create a new confidentiality privilege but clarified the existing one. The court held that the amendment could be applied retroactively and did not violate the Oklahoma Constitution. The court affirmed the district court's decision, concluding that the DOC's refusal to provide the requested records was lawful under the amended statute. View "HODARA v. OKLAHOMA DEPARTMENT OF CORRECTIONS" on Justia Law

The case involves a challenge to Oklahoma's H.B. 1775, which prohibits mandatory gender or sexual diversity training and restricts the teaching of certain concepts related to race and sex in public schools and higher education institutions. Plaintiffs, including the Black Emergency Response Team and other organizations, argue that the law is unconstitutional under the First and Fourteenth Amendments, claiming it is vague, overbroad, and imposes viewpoint-based restrictions.The United States District Court for the Western District of Oklahoma reviewed the case and certified several questions of state law to the Oklahoma Supreme Court. The district court granted in part and denied in part motions from both plaintiffs and defendants, enjoining certain provisions of the law as unconstitutionally vague. Specifically, the court enjoined the enforcement of the second sentence of § 24-157(A)(1) and parts of § 24-157(B)(1).The Oklahoma Supreme Court addressed the certified questions, determining that the term "requirement" in § 24-157(A)(1) pertains only to orientation requirements and does not apply to classes, courses, or curricular speech. The court declined to answer the remaining certified questions related to § 24-157(B)(1), stating that the terms and phrases in question could be interpreted using their common, ordinary meanings and that the federal court could undertake this task. The court also noted that answering these questions would not avoid or alter the constitutional challenge to the statute and could result in an advisory opinion. View "BLACK EMERGENCY RESPONSE TEAM v. DRUMMOND" on Justia Law

A limited partnership, owning an apartment complex in Norman, Oklahoma, transferred its general and limited partnership interests to new owners in 2022. The Cleveland County Assessor subsequently increased the fair cash value of the property from $18,437,401 in 2022 to $42,500,000 in 2023, exceeding the constitutionally allowed 5% annual increase for ad valorem taxation. The partnership, Icon, protested this increase, arguing that the transfer of partnership interests did not constitute a transfer of property title.The Cleveland County Board of Equalization denied Icon's protest, and the Oklahoma Court of Tax Review granted summary judgment in favor of the Assessor, concluding that the transfer of partnership interests was equivalent to a transfer of property title, thus lifting the 5% cap on valuation increases. Icon appealed this decision.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on whether the transfer of partnership interests should be treated as a transfer of property title under Okla. Const. art. 10, §8B. The court held that the transfer of partnership interests was a transfer of personal property, not real property, and did not constitute a transfer, change, or conveyance of the property title. Therefore, the 5% cap on annual increases in property valuation for ad valorem taxation should not have been lifted. The court vacated the Oklahoma Court of Tax Review's order and remanded the case. View "THE ICON AT NORMAN APTS, LP v. DOUGLAS WARR, CLEVELAND COUNTY ASSESSOR" on Justia Law

The case involves Oklahoma Gas and Electric Company (OG&E) and CKenergy Electric Cooperative, Inc. (CKenergy) regarding the provision of retail electric service to two facilities located in CKenergy's certified territory. OG&E began providing service to these facilities in 2017 and 2018, respectively. CKenergy filed an application with the Oklahoma Corporation Commission (the Commission) in 2019, requesting that OG&E be enjoined from continuing to serve the facilities, arguing that OG&E was in violation of the Retail Energy Supplier Certified Territory Act (RESCTA). OG&E contended that it was allowed to serve the facilities under the one megawatt exception of RESCTA.The Commission found that the connected load for initial full operation did not meet or exceed 1,000 kW at either facility and enjoined OG&E from providing service. OG&E appealed the Commission's order. The Commission also issued an order granting OG&E's request for a stay upon posting a supersedeas bond, which CKenergy and the Oklahoma Association of Electric Cooperatives (OAEC) appealed.The Supreme Court of the State of Oklahoma reviewed the case de novo. The Court held that the term "connected load for initial full operation" in the one megawatt exception of RESCTA refers to the total nameplate values of all connected electrical equipment when full operation of the facility commences. The Court found that the Commission's interpretation ignored the plain language of the statute and was not sustained by law. It was undisputed that the connected load for each facility exceeded 1,000 kW when full operation commenced. Therefore, the one megawatt exception applied, and the Commission improperly enjoined OG&E from providing service. The Court reversed the Commission's order and deemed the appeal regarding the stay moot. View "OG&E Co. v. OKLAHOMA CORPORATION COMMISSION" on Justia Law

A contractor, Flintco, LLC, entered into a subcontract with Total Installation Management Specialists, Inc. (Total) for flooring work on a construction project at Oklahoma State University. Total was required to secure a performance bond from Oklahoma Surety Company (OSC). Flintco later supplemented Total's workforce due to delays and performance issues but did not notify OSC until five weeks after taking over the work.The Tulsa County District Court ruled in favor of Flintco, awarding damages against Total and OSC. OSC appealed, arguing that Flintco failed to meet the performance bond's conditions requiring a declaration of default and reasonable notice before assuming control of the work. The Court of Civil Appeals reversed the district court's judgment, finding that the notice requirement was a mandatory condition precedent, and Flintco's failure to provide timely notice relieved OSC of liability.The Supreme Court of the State of Oklahoma reviewed the case and agreed with the Court of Civil Appeals. The court held that the performance bond's notice requirement constituted a mandatory condition precedent. Flintco's failure to provide timely notice to OSC so it could exercise its performance options under the bond relieved OSC from liability. The court vacated the Court of Civil Appeals' opinion, reversed the district court's judgment, and remanded the case with instructions to enter judgment consistent with this decision. The trial court's judgments against Total were not affected by this decision. View "Flintco, LLC v Total Installation Management Specialists, Inc." on Justia Law