Justia Oklahoma Supreme Court Opinion Summaries

Survivors of the 1921 Tulsa Race Massacre and representatives of the estate of a deceased survivor filed a lawsuit against the City of Tulsa, the Tulsa Regional Chamber, the Board of County Commissioners for Tulsa County, the Sheriff of Tulsa County, and the Oklahoma Military Department. The plaintiffs alleged that the defendants' actions and omissions, beginning with the massacre and continuing to the present day, constituted a public nuisance. They also claimed that the defendants had unjustly enriched themselves by exploiting the massacre for their own economic and political gain.The District Court of Tulsa County dismissed the plaintiffs' claims. It found that the plaintiffs had failed to state a justiciable public nuisance claim and had not proposed a legally cognizable abatement remedy. The court also dismissed the unjust enrichment claim, citing a failure to correct a defective pleading.The plaintiffs appealed to the Supreme Court of the State of Oklahoma. They argued that the district court had erred in dismissing both their public nuisance and unjust enrichment claims. The Supreme Court retained the case for review.The Supreme Court affirmed the district court's decision. It held that the plaintiffs' grievances did not fall within the scope of Oklahoma's public nuisance statute. The court also found that the plaintiffs' allegations did not support a claim for unjust enrichment under the equitable doctrine. The court noted that the plaintiffs' grievances were legitimate but stated that the law did not permit the court to extend the scope of the public nuisance doctrine or the doctrine of unjust enrichment to provide the plaintiffs with the justice they sought. View "Randle v. City of Tulsa" on Justia Law

The case revolves around the issue of whether a guardian can initiate a divorce proceeding on behalf of an incapacitated ward. Peter Galbraith, II, the ward, and Belinda Galbraith were married in 2015. Between 2018 and 2019, Mr. Galbraith became ill with Frontotemporal Dementia BV. Mrs. Galbraith obtained a power of attorney and later deeded the marital residence to her separate trust. In 2022, she asked Mr. Galbraith's brother and mother to take care of him, and he was moved out of the marital home. In 2023, Mr. Galbraith's brother and mother petitioned the court for a general guardianship over him and filed a Petition for the Dissolution of Marriage without first obtaining authorization from the guardianship court. Mrs. Galbraith filed a motion for summary judgment alleging the guardians lacked authority to initiate a divorce proceeding on behalf of the ward. The trial court agreed and granted the motion.The trial court initially held that the guardian did not have the authority to file a divorce petition on behalf of the ward. After obtaining authorization from the guardianship court, the guardian refiled the petition. However, the trial court again dismissed the petition, stating that Oklahoma law does not allow a guardian to initiate a divorce on behalf of a ward. The guardian appealed this decision to the Supreme Court of the State of Oklahoma.The Supreme Court of the State of Oklahoma reversed the trial court's decision. The court held that the Oklahoma Guardianship and Conservatorship Act does not explicitly disallow the guardianship court from authorizing a guardian to file a divorce petition on behalf of a ward. The court found that the guardian was acting to protect the ward's rights and manage his financial resources, which aligns with the purpose of the Act. The court also held that the addressed provisions of title 43 of the Oklahoma Statutes do not act as a bar to the initiation of such an action by the guardian. The court concluded that the guardianship court may authorize a guardian to initiate a divorce action on behalf of a ward. The case was remanded for further proceedings. View "GALBRAITH v. GALBRAITH" on Justia Law

The case revolves around a dispute between Sheena Hayes and Morgan Lawrence-Hayes, and Richard Penkoski. The dispute arose from Penkoski's social media posts, which the Hayes couple claimed were harassing and stalking. Penkoski, a public figure who identifies as a pastor, activist, and street preacher, posted content on Facebook criticizing the Hayes couple's church and their organization, Oklahomans for Equality. The Hayes couple, who are also public figures, claimed that they and their minor child were pictured in the posts, which they found offensive and threatening.The Hayes couple obtained a protective order against Penkoski from the District Court of Washington County. The court issued a permanent order of protection for five years, prohibiting Penkoski from posting any pictures, images, videos, or any likenesses of the Hayes couple or their minor child on any social media, making reference to them, or coming within 500 feet of them.Penkoski appealed the decision, arguing that his actions did not meet the requirements of stalking or harassment as defined by the Protection from Domestic Abuse Act, and that his posts were protected by his constitutional right to free speech.The Supreme Court of the State of Oklahoma reversed the lower court's decision. The court found that Penkoski's actions were not directed toward an individual person, but rather were public Facebook posts that named two organizations, not individuals. The court concluded that Penkoski did not direct his posts or comments toward the Hayes couple, and therefore, the district court abused its discretion in issuing the order of protection. The court vacated the order of protection. View "Hayes v. Penkoski" on Justia Law

The case revolves around an incident where an employee, Leonard Bernstein, shot his co-worker, Christopher Bayouth, at their workplace, Morgan Stanley's Oklahoma City branch. Bernstein, who was suffering from mental deficiencies, believed he was acting in self-defense due to his delusional state. After the shooting, Bayouth filed a lawsuit against Bernstein for willful and intentional acts, assault, battery, and intentional infliction of emotional distress. Bernstein passed away, and his estate was substituted as the defendant. The estate argued that Bayouth's exclusive remedy was through the Administrative Workers' Compensation Act (AWCA), as he had received workers' compensation benefits.The District Court of Oklahoma County granted summary judgment in favor of Bernstein's estate, ruling that the exclusive remedy provision of the AWCA protected Bernstein regardless of whether he was acting within his course and scope of employment when the shooting occurred. The court reasoned that the focus was on whether the injured employee was acting within the course and scope of his employment at the time of the incident, not the employee who caused the injury.The Supreme Court of the State of Oklahoma disagreed with the lower court's interpretation. The court held that for the exclusive remedy provision under the AWCA to apply, the employee who injures another employee must be acting within the course and scope of their employment when the incident occurs. The court found that the parties disputed whether Bernstein was acting within the course and scope of his employment when he shot Bayouth. Therefore, the court reversed the lower court's decision and remanded the case for further proceedings. View "Bayouth v. Dewberry" on Justia Law

The case revolves around a lodging tax increase proposal in McCurtain County, Oklahoma, intended to fund a new county hospital. The Board of County Commissioners for McCurtain County approved the proposal to be submitted to the voters. However, the Board did not publish the proposal in a county newspaper for four weeks before the election as required by Title 19 O.S. 2021 §383. Instead, the Board and the Hospital engaged in a three-month campaign to inform voters of the measure through various means such as radio advertisements, billboards, newspaper articles, town hall meetings, and social media posts. After the measure was approved by the voters, a lodging renter and property owner filed a lawsuit seeking to have the election declared null and void due to the lack of newspaper publication. The Hospital sought to have the election upheld.The District Court of McCurtain County, Oklahoma, granted summary judgment in favor of the Board and Hospital, and against the lodging renter and property owner. The renter and owner appealed the decision.The Supreme Court of the State of Oklahoma held that because the county commissioners neglected to follow the statutory publication requirements, the voter-approved lodging tax increase is invalid. The court emphasized that the Legislature has mandated what constitutes adequate notice by publication and anything less than strict compliance requires the court to invalidate the election. The court also encouraged the legislature to consider revisiting and possibly updating publication requirements to be more compatible with today's methods of communication. The decision of the lower court was reversed. View "Cathey v. Board of County Commissioners for McCurtain County" on Justia Law

The case involves the Edmond Public Schools (the Petitioner) and the State of Oklahoma, the State Board of Education, and the State Superintendent of Public Instruction (the Respondents). The Petitioner filed an application for the Supreme Court to prevent the enforcement of rules by the Respondents. These rules were to be used in enforcement proceedings against the school district before the State Board. The Petitioner argued that the State Board lacked the authority to supervise, examine, and control a local school board's discretion in supplying books for a school library that meet local community standards.The State Board of Education had publicized proposed rules for school library media programs, which included prohibitions on pornographic and sexualized content for books and other media. The Board adopted these rules, citing the Oklahoma Constitution and state statutes as their authority. However, the Oklahoma Attorney General issued an opinion stating that the proposed rules were not based on a specific grant of legislative authority, which was necessary for the Board to create these rules. The Legislature passed a resolution that did not expressly approve or disapprove the State Board's new rules. The Governor later issued a Declaration stating that the proposed rules for the State Department of Education were not subject to the joint resolution and approved these proposed rules as permanent rules for the State Department of Education.The Supreme Court of the State of Oklahoma assumed original jurisdiction, in part, over the controversy. The court held that state statutes give a local school board power and a type of statutory discretion to supply books for a school library that meet local community standards. The court also held that no statute gives the State Board of Education, State Department of Education, and Superintendent of Public Instruction the authority to supervise, examine, and control a local school board's exercise of this discretion when the local school board applies local community standards for books it supplies for a local school library. The court issued a writ of prohibition to prevent additional enforcement proceedings against the school district based on the respondents' objection to the presence of certain books in the local school library. The court denied the petitioner's request for declaratory and injunctive relief. View "INDEPENDENT SCHOOL DISTRICT NO. 12 v. STATE" on Justia Law

The case revolves around a tort action brought by the widow of a deceased worker against various entities, including the employer, Oklahoma Gas and Electric Company, and others involved in the construction project where the accident occurred. The widow alleged that these entities failed to provide proper supervision and safety protocols, leading to her husband's death. The employer, BJ's Oilfield Construction, Inc., filed a motion to dismiss a third-party petition filed against it by one of the defendants, SunPower Corporation Systems. The District Court sustained the motion to dismiss, leading to an appeal.In the lower courts, the widow's wrongful death claim was initially dismissed, leading to three separate appeals. The dismissals were based on the defendants identifying themselves with "prime contractor" status. The appellate court reversed the dismissals, stating that the defendants' assertions were unsupported. The cases were remanded back to the District Court.The Supreme Court of the State of Oklahoma reversed the District Court's order dismissing SunPower's third-party petition against BJ's Oilfield. The court held that the exclusive remedy and liability language in the workers' compensation law does not prevent an employer from creating non-employer legal relationships, capacities, or roles. However, these relationships, capacities, or roles cannot create a negligence tort liability for the same physical injury used by a party for a compensable workers' compensation award. The court also held that the language of the workers' compensation law does not prohibit an employer from creating an indemnity agreement holding others harmless for the employer's intentional conduct not subject to exclusive workers' compensation remedies. The case was remanded for additional proceedings. View "KNOX v. OKLAHOMA GAS AND ELECTRIC CO." on Justia Law

Latigo Oil & Gas, Inc., an Oklahoma corporation, filed a lawsuit against BP America Production Company, a Delaware corporation, to enforce its preferential right to purchase certain mineral interests that BP had offered for sale as part of a package deal to a third party. Prior to trial, Latigo requested a temporary restraining order and preliminary injunctive relief to prevent BP from selling the interests to the third-party buyer pending trial. The trial court granted Latigo's request for preliminary injunctive relief.The Court of Civil Appeals reversed the trial court's decision, finding that the evidence did not show Latigo was likely to succeed on the merits. The court held that BP did not owe Latigo a duty to provide a good-faith allocation of value to the interests burdened by Latigo's preferential right. It found that whether the allocations provided by BP were inflated as alleged by Latigo was irrelevant, as the notices provided by BP met the terms of the operating agreements.The Supreme Court of the State of Oklahoma granted certiorari and held that the trial court's grant of injunctive relief was not an abuse of discretion. The court noted that while there was no binding precedent on whether an allocation of value within a package deal must be made in good faith, substantial support for Latigo's position could be found in both Oklahoma precedent and in other jurisdictions. The court affirmed the trial court's decision to grant preliminary injunctive relief and remanded for further proceedings consistent with its opinion. View "LATIGO OIL & GAS v. BP AMERICA PRODUCTION CO." on Justia Law

The case involves Nancy Anaya-Smith, the next of kin of Michael Brian Smith, who was killed in a single-car accident while he was a passenger in a company vehicle owned by Fixtures & Drywall Company of Oklahoma (FADCO). The vehicle was being driven by Smith's coworker, Duane Clark. Anaya-Smith alleges that Clark's negligence caused the fatal accident. At the time of the accident, FADCO maintained an insurance policy with Federated Mutual Insurance Company (Federated). The policy provided up to $1,000,000 of liability coverage per accident and an additional $6,000,000 of liability coverage per accident under an umbrella policy. However, FADCO had rejected uninsured motorist (UM) coverage for all employees, except for its directors, officers, partners, owners, and their family members.The United States District Court for the Western District of Oklahoma granted summary judgment in favor of Federated, concluding that the vehicle was an uninsured vehicle at the time of the accident because Clark is immune from tort liability under the workers' compensation exclusive remedy provision, and that FADCO's policy providing UM coverage for some individuals who qualify as insureds but rejecting UM coverage for other insureds does not violate Oklahoma law. Anaya-Smith appealed from the summary judgment order.The Supreme Court of the State of Oklahoma answered the first certified question in the affirmative, holding that the vehicle qualifies as an uninsured motor vehicle within the meaning of Oklahoma law. The court answered the second certified question in the negative, concluding that the plain language of Oklahoma law requires a named insured to either elect or reject uninsured/underinsured motorist coverage for all insureds under the policy, treating every insured in the same manner. The court declined to answer the third certified question as the record was undeveloped and the parties did not submit legal arguments pertaining to it. View "Anaya-Smith v. Federated Mutual Insurance Co." on Justia Law

The Supreme Court of the State of Oklahoma reviewed the termination of parental rights of Victoria Rodriguez and Everardo Rodriguez, Sr., parents of four children who were adjudicated deprived. The children were removed from their parents' custody following allegations of severe sexual abuse against the eldest daughter, M.R., by her father over a two-year period, and the mother's failure to protect the children from this abuse.The District Court of Oklahoma County terminated the parents' rights after a jury trial. Both parents appealed separately, and their appeals were considered together in this opinion. The mother argued that the Indian Child Welfare Act (ICWA) was unconstitutional as it denied her equal protection under the law. However, the court found that she lacked standing to challenge the constitutionality of ICWA. The court also held that the trial court did not violate her right to equal protection under the law by failing to apply a heightened burden of proof under ICWA.The father argued that the trial court erred by not making certain required findings under federal and state law and by granting the State's Motion in Limine. The court found that the trial court did not err in these respects. The court affirmed the trial court's orders terminating the parental rights of both parents. View "In the Matter of M.R." on Justia Law