Justia Oklahoma Supreme Court Opinion Summaries

Petitioners, resident taxpayers and registered voters in Oklahoma County, challenged the constitutionality of Senate Bill 632, which sought to create business court divisions within the district courts of Oklahoma County and Tulsa County. The Act provided for the appointment of business court judges by the Governor, with confirmation by the Senate and candidate lists supplied by the Speaker of the House. It also set forth qualifications, terms, salaries, and operational details for these judges and courts. Petitioners argued that the Act violated their constitutional rights, particularly the right to elect district judges, and would result in the unlawful expenditure of public funds.Prior to review by the Supreme Court of the State of Oklahoma, the Honorable Lonnie Paxton and Kyle Hilbert, legislative leaders named as respondents, moved for dismissal based on legislative immunity, which the court granted. The Governor, the remaining respondent, moved to dismiss the case, arguing he was not a proper party. The court denied this motion, finding the Governor’s role in appointing business court judges central to the dispute. The Oklahoma Association for Justice filed an amicus brief supporting Petitioners. The court assumed original jurisdiction, issued a temporary stay of the Act’s effectiveness, and heard oral arguments.The Supreme Court of the State of Oklahoma held that Petitioners had standing as both taxpayers and voters. The court found Senate Bill 632 unconstitutional because it violated Article VII, Section 9 of the Oklahoma Constitution by circumventing the requirement that district judges be elected by voters. The court further determined that the unconstitutional provisions were not severable from the rest of the Act, rendering the entire Act void and unenforceable. The petition for declaratory relief was granted, and the temporary stay remained in effect pending any rehearing. View "White v. Stitt" on Justia Law

A nursing home resident’s legal representative, acting under a durable power of attorney, sued a nursing home for alleged medical negligence during the resident’s stay. Upon admission, the representative signed several documents, including an agreement to arbitrate any disputes arising from the resident’s care. The representative later claimed not to recall signing the documents but did not dispute her signature. The nursing home moved to compel arbitration based on the signed agreement, which expressly stated it was governed by the Federal Arbitration Act (FAA).The District Court of McCurtain County, Oklahoma, held a hearing on the motion to compel arbitration. The court found that a valid arbitration agreement existed, signed by both an authorized agent of the nursing home and the legal representative. The court determined that the FAA applied due to the involvement of interstate commerce and that the Oklahoma Nursing Home Care Act’s (NHCA) prohibition of arbitration agreements was preempted by federal law. The court granted the nursing home’s motion to compel arbitration and stayed the judicial proceedings.The Supreme Court of the State of Oklahoma reviewed the case de novo. It affirmed the district court’s decision, holding that the FAA preempts the NHCA’s categorical prohibition of arbitration agreements in the nursing home context when interstate commerce is involved and the agreement expressly invokes the FAA. The court found the arbitration agreement was validly executed and not unconscionable, distinguishing this case from prior Oklahoma precedent and aligning with the United States Supreme Court’s decision in Marmet Health Care Center, Inc. v. Brown. The Supreme Court of Oklahoma affirmed the district court’s order compelling arbitration. View "Thompsonl v. Heartway Corp." on Justia Law

The plaintiff sought medical care for severe headaches and related symptoms from various providers in Oklahoma and Missouri, including Freeman Health System (FHS) and Dr. Gulshan Uppal in Joplin, Missouri. After multiple visits and treatments, she was ultimately diagnosed with serious neurological conditions and suffered lasting health consequences. She alleged that several healthcare providers, including FHS and Dr. Uppal, negligently diagnosed, treated, and discharged her.She filed suit in the District Court of Ottawa County, Oklahoma, naming multiple defendants. FHS and Dr. Uppal moved to dismiss for lack of personal jurisdiction, arguing their actions and contacts were insufficient for Oklahoma courts to exercise jurisdiction. The district court granted the motion, finding it lacked both general and specific personal jurisdiction over these defendants, primarily because the relevant treatment occurred in Missouri and the claims did not arise from FHS’s Oklahoma contacts. The Oklahoma Court of Civil Appeals affirmed this decision.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the district court erred by only considering whether the suit “arose out of” the defendants’ contacts with Oklahoma, and not whether it “related to” those contacts, as required by the two-pronged standard for specific personal jurisdiction clarified in Ford Motor Co. v. Montana 8th Judicial District Court. The Supreme Court found that the plaintiff met her burden regarding FHS’s contacts with Oklahoma, warranting further proceedings to determine if her claims “relate to” those contacts. However, the plaintiff failed to show sufficient contacts for personal jurisdiction over Dr. Uppal. The Supreme Court vacated the appellate court’s opinion, affirmed the district court’s dismissal of Dr. Uppal, reversed the dismissal of FHS, and remanded for further proceedings. View "Barfell v. Freeman Health System" on Justia Law

Several homeowners initiated a lawsuit against an individual, alleging conversion, trespass, outrage, reformation of restrictive covenants, quiet title, and seeking injunctive relief to prevent interference with their use of common areas in a real estate development. The defendant retained counsel and filed a timely answer. However, when the homeowners moved for summary judgment, the defendant’s attorney failed to respond or inform his client about the motion. The district court granted summary judgment for the homeowners, awarding substantial actual and punitive damages, as well as attorney’s fees, far exceeding the amount requested in the motion.After more than 30 days had passed since judgment, the defendant moved to vacate the judgment in the District Court of Cherokee County, Oklahoma, arguing that unavoidable casualty or misfortune, fraud, and irregularity had prevented him from defending the action. The district court held an evidentiary hearing and denied the motion to vacate. The defendant appealed, and the Court of Civil Appeals, Division III, affirmed the district court’s decision, finding that the defendant had not properly pled a valid defense and that his attorney’s negligence was imputed to him.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the attorney’s abandonment of the case without the client’s knowledge, combined with a breakdown in office procedures and lack of communication, constituted unavoidable casualty or misfortune under Oklahoma law. The court further found that the district court’s award of damages and attorney’s fees without a hearing or proper evidentiary support violated the defendant’s due process rights. The Supreme Court vacated the opinion of the Court of Civil Appeals, reversed the district court’s judgment, and remanded the case for further proceedings. It also vacated the appellate attorney fee award previously granted to the homeowners. View "Bjorkman v. Noble" on Justia Law

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