Justia Oklahoma Supreme Court Opinion Summaries

Charter Oak Production Co., LLC paid to settle a property damage claim after a pipeline installed on its easement ruptured, causing a saltwater spill on the property of Jason and Melissa Mills. Charter Oak sought indemnity from JM Eagle, Inc., the manufacturer, and Rainmaker Sales, Inc., the distributor, alleging the pipe was defective. The district court granted summary judgment in favor of JM Eagle and Rainmaker, finding that Charter Oak lacked the necessary legal relationship to assert an indemnity claim and that the claim was barred by the economic loss rule.The Oklahoma Court of Civil Appeals, Division IV, reversed the district court's decision. It found that Charter Oak's non-delegable duty to the Millses created the legal relationship necessary to support an indemnity claim against JM Eagle and Rainmaker. Additionally, it held that Charter Oak's claim was not barred by the economic loss rule.The Supreme Court of the State of Oklahoma reviewed the case. It held that Charter Oak's non-delegable duty as the dominant tenant of the easement established the legal relationship necessary to seek indemnity from JM Eagle and Rainmaker. The court also held that the economic loss rule did not bar Charter Oak's indemnity claim, as it sought reimbursement for damage to property other than the defective product itself. Consequently, the Supreme Court vacated the Court of Civil Appeals' decision, reversed the district court's order, and remanded the case for further proceedings consistent with its opinion. View "Mills v. J-M Mfg. Co., Inc." on Justia Law

Cynthia Maldonado and Martha Amaro, who lived on both sides of the Oklahoma-Kansas border and in Mexico, appealed a trial court's order that Oklahoma had jurisdiction over a juvenile deprived proceeding under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The trial court found that Maldonado's child, L.A., had resided in Oklahoma for six months preceding the commencement of the proceeding, making Oklahoma the child's home state. The court also adjudicated the children deprived as to Maldonado.The Texas County District Court of Oklahoma ordered that N.A. and L.A. be taken into emergency custody by the Oklahoma Department of Human Services (OKDHS) after Maldonado and N.A. tested positive for methamphetamine at birth. Maldonado filed a motion arguing that Oklahoma did not have jurisdiction under the UCCJEA, claiming that Mexico and Kansas were the children's home states. The State argued that Oklahoma had jurisdiction under the Oklahoma Children's Code. The trial court found that L.A. had lived in Oklahoma for six months before the proceeding and adjudicated the children deprived.The Supreme Court of the State of Oklahoma reviewed the case and affirmed the trial court's findings. The court held that the Oklahoma district court had subject matter jurisdiction over the juvenile deprived proceeding and that the UCCJEA applied to such proceedings. The court found that the trial court's determination that L.A. had resided in Oklahoma for six months preceding the proceeding was not clearly erroneous. The court also affirmed the trial court's order adjudicating the children deprived as to Maldonado, finding competent evidence to support the order. The appeal was not considered moot due to ongoing collateral consequences. View "IN RE: N.A.; STATE OF OKLAHOMA vs MALDONADO" on Justia Law

An Assistant District Attorney (ADA) was accused of misconduct for observing jury deliberations during a first-degree murder trial. The ADA entered a security office where the jury's deliberations were being monitored via security cameras and watched the proceedings for over two hours. The ADA did not disclose this to the judge or opposing counsel and later misrepresented the reasons for his actions and the duration of his observation.The Professional Responsibility Tribunal found clear and convincing evidence that the ADA violated several rules, including conduct prejudicial to the administration of justice and engaging in deceit or misrepresentation. The Tribunal recommended public censure and assessment of costs.The Supreme Court of Oklahoma reviewed the case de novo and found that the ADA's actions violated multiple rules of professional conduct, including committing a criminal act that reflects adversely on the lawyer's trustworthiness, engaging in deceit or misrepresentation, and conduct prejudicial to the administration of justice. The Court determined that the appropriate discipline was a six-month suspension due to the serious nature of the misconduct, which undermined public trust in the legal system and brought discredit upon the legal profession.The Court also granted the amended application to assess costs against the ADA, totaling $6,104.91. The ADA was ordered to comply with the Rules Governing Disciplinary Proceedings and to pay the assessed costs within ninety days. View "STATE OF OKLAHOMA ex rel. OBA v. SHIELDS" on Justia Law

Philip Sanders filed a petition in the District Court for Creek County, alleging that Turn Key Health Clinics, LLC caused the wrongful death of his wife, Brenda Jean Sanders, during her confinement in the Creek County Jail. Brenda Sanders was booked into the jail on October 17, 2016, and her health deteriorated over four weeks. She was transported to a hospital on November 20, 2016, diagnosed with severe sepsis and other conditions, and died the next day.The District Court granted Turn Key's motion to dismiss Sanders' petition, citing immunity under the Oklahoma Governmental Tort Claims Act, and allowed Sanders thirty days to amend his petition. Sanders did not amend and appealed the dismissal. The Court of Civil Appeals reversed the District Court's order, but Turn Key filed a petition for certiorari to review the appellate court's decision. The Supreme Court of Oklahoma granted certiorari.The Supreme Court of Oklahoma held that Sanders' appeal was premature as it challenged an interlocutory order, and appellate jurisdiction was absent. The Court vacated the opinion of the Court of Civil Appeals and withdrew it from publication. The Court recast Sanders' petition in error as an application to assume original jurisdiction and a petition for prohibition. The Court concluded that the Governmental Tort Claims Act makes licensed medical professionals "employees" of the state when under contract with city, county, or state entities and providing medical care to inmates or detainees. The Court assumed original jurisdiction and denied the petition for a writ of prohibition. View "Sanders v. Turn Key Health Clinics, LLC" on Justia Law

Grant Phillip Poppinga filed a paternity petition seeking custody, visitation, and support for his daughter with Arrianna Monet Wallace. Unable to locate Wallace, Poppinga attempted service by publication. When Wallace did not appear, Poppinga moved for a default judgment, which the district court granted, establishing his paternity and awarding him sole custody. Wallace later sought to vacate the judgment, citing errors in the service by publication and the default judgment. The district court denied her motion, and she appealed.The Oklahoma Supreme Court reviewed the case, focusing on the sufficiency of the service by publication and the district court's denial of Wallace's motion to vacate. The court found multiple errors in the service by publication, including misspellings, incorrect nature of the suit, and untimely publication. These errors were deemed fatal to the court's jurisdiction over Wallace. Additionally, the court noted that the trial court failed to conduct a proper judicial inquiry into the due diligence of Poppinga's search for Wallace.The Oklahoma Supreme Court held that the district court abused its discretion in finding the service by publication sufficient and in denying Wallace's motion to vacate the default judgment. The court emphasized the importance of due process, particularly in cases involving fundamental parental rights. The court reversed the district court's decision and remanded the case for further proceedings, instructing the trial court to reconsider Wallace's motion to dismiss for lack of jurisdiction and insufficiency of service of process, and to conduct further proceedings consistent with the opinion. View "POPPINGA v. WALLACE" on Justia Law

In the spring of 2018, People's Electric Cooperative and Oklahoma Gas and Electric Company (OG&E) submitted competing bids to provide retail electric service to the Tall Oak Woodford Cryo Plant in Coal County, Oklahoma. The Plant is located in People's certified territory, which grants them exclusive rights to provide electricity under the Retail Electric Supplier Certified Territory Act (RESCTA). OG&E's proposal relied on the Large Load exception to RESCTA, which allows a supplier to extend its service into another supplier's territory for large-load customers. OG&E used third-party transmission facilities to provide service to the Plant without extending its own distribution lines.The Oklahoma Corporation Commission enjoined OG&E from serving the Plant, finding that OG&E was not "extending its service" as authorized by RESCTA. The Commission determined that a retail electric supplier may not use third-party transmission lines to extend its service into another supplier's certified territory under the Large Load exception. OG&E appealed the decision.The Supreme Court of the State of Oklahoma reviewed the case and upheld the Commission's determination. The Court held that Article 9, Section 20 of the Oklahoma Constitution requires a limited review of the Commission's order. The Court affirmed the Commission's interpretation that the Large Load exception does not permit a supplier to use third-party transmission lines to extend its service into another supplier's certified territory. The Court's decision applies prospectively only and does not affect existing retail electric services and facilities established under the Large Load exception. View "OKLAHOMA GAS AND ELECTRIC CO. v. STATE" on Justia Law

Jai Hospitality, LLC (Jai) sued Western World Insurance Company (Western World) after Western World denied Jai's claim for damages from a fire at Jai's motel, arguing that the insurance policy had expired. Jai contended that Western World failed to provide proper notice of nonrenewal or a renewal offer with a premium increase, which should have extended the policy term. Western World argued that it was not required to send notice directly to Jai and that the policy expired on June 1, 2020. Jai obtained replacement insurance in July 2020, after the fire.The District Court of Garvin County initially denied both parties' motions for summary judgment. Upon reconsideration, the court granted Western World's motion, finding that Western World made a timely, legally effective offer to renew the policy and was not required to send the offer directly to Jai. The Court of Civil Appeals affirmed the trial court's judgment, agreeing that notice to Jai's insurance agent constituted notice to Jai.The Supreme Court of the State of Oklahoma reviewed the case and held that the trial court erred in finding that Western World was not required to send its renewal offer directly to Jai. The court determined that the terms of the insurance contract and Oklahoma law required Western World to provide written notice of a renewal offer with a premium increase directly to the first named insured. The court concluded that notice to Jai's insurance agent did not satisfy this requirement. Consequently, the Court of Civil Appeals' opinion was vacated, the District Court's order was reversed, and the matter was remanded for further proceedings. View "Jai Hospitality, LLC v. Western World Insurance Co." on Justia Law

Claudia C. Conner, the plaintiff, was employed by the Oklahoma Employment Security Commission (OESC) as General Counsel and Chief of Staff. She was terminated in November 2021, at the age of over sixty, despite having satisfactory job performance and receiving a raise a month prior. Conner alleges that her termination was due to age and gender discrimination, and retaliation for reporting sexual harassment by a state vendor. She filed a charge of discrimination with the EEOC, which issued a right to sue letter, leading her to file a lawsuit in the Oklahoma County District Court.The OESC moved to dismiss the case, arguing that Conner failed to comply with the notice provisions of the Governmental Tort Claims Act (GTCA). The District Court of Oklahoma County denied the motion, citing material conflicts between the GTCA and the Oklahoma Anti-Discrimination Act (OADA). The OESC then sought and was granted a petition for certiorari to the Supreme Court of the State of Oklahoma.The Supreme Court of the State of Oklahoma reviewed the case and held that there are no material or irreconcilable conflicts between the GTCA and the OADA regarding the notice provisions. The court found that the GTCA's notice requirements apply to claims under the OADA. Consequently, the trial court's denial of the motion to dismiss was reversed, and the case was remanded for further proceedings consistent with this opinion. The Supreme Court emphasized that compliance with the GTCA notice provisions is a jurisdictional requirement for tort suits against governmental entities. View "CONNER v. STATE" on Justia Law

Tracy L. Clark and Edward A. Clark filed a petition for the appointment of guardians of two minor children, K.D.B. and K.M.B., who are enrolled members of the Cherokee Nation, in Rogers County District Court in 2013. The district court granted temporary guardianship to the Clarks, and the Cherokee Nation intervened, noting their right to be involved under the Indian Child Welfare Act (ICWA). In 2021, the Cherokee Nation requested a transfer of the case to the Cherokee Nation District Court, citing an Intergovernmental Agreement with the State of Oklahoma regarding jurisdiction over Indian children within the Nation's reservation.The Rogers County District Court granted the motion to transfer the case to the Cherokee Nation District Court, finding that the children were domiciled on the Cherokee Nation Reservation and that the Agreement mandated the transfer. The Clarks objected, arguing that the Agreement could not redefine "reservation" and that the children did not reside within the reservation. The district court stayed the transfer pending appeal.The Supreme Court of the State of Oklahoma reviewed the case and affirmed the district court's decision. The court held that the Cherokee Nation Reservation was never disestablished and that the children were domiciled within the reservation, thus falling under the jurisdiction of the Cherokee Nation as per the ICWA and the Agreement. The court found that the Agreement was valid and applicable, and that the transfer to tribal court was mandatory under its terms. The court also rejected the Clarks' arguments regarding waiver, retroactivity, and due process violations. The case was remanded to the Rogers County District Court to lift the stay and transfer the case to the Cherokee Nation District Court. View "In re Guardianship of K.D.B." on Justia Law

Kelly Patrick Donaldson was convicted of second-degree rape in 2005 and became subject to the Sex Offenders Registration Act (SORA). At that time, SORA did not prohibit sex offenders from residing near parks. The Oklahoma Legislature later amended the law to prohibit sex offenders from living within 2,000 feet of a city park. In 2021, Donaldson sought to live in El Reno, Oklahoma, but was informed by the police that the property he intended to purchase was within 310 feet of a city park, violating the amended residency restrictions.The District Court of Canadian County granted summary judgment in favor of Donaldson, ruling that applying the 2019 residency restrictions to him violated the ex post facto clauses of the federal and state constitutions. The court found that the version of SORA in effect at the time of Donaldson's conviction should apply, which did not include the park residency restriction.The Supreme Court of the State of Oklahoma reviewed the case and reversed the lower court's decision. The court held that the residency restrictions in 57 O.S.Supp.2019, § 590(A) do not amount to punishment and therefore do not violate the ex post facto clause. The court determined that the legislative intent behind SORA was civil and regulatory, aimed at protecting the public and reducing recidivism, rather than punitive. Consequently, the current residency restrictions apply to all sex offenders, regardless of when they became subject to SORA. The case was remanded for further proceedings to determine whether Lake El Reno qualifies as a park under the statute and if the property in question falls within the restricted area. View "DONALDSON v. CITY OF EL RENO" on Justia Law