Justia Oklahoma Supreme Court Opinion Summaries

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

The case revolves around a contract dispute over roofing work done in conjunction with the purchase of a house. The appellant, Carl Fleig, had purchased a house from homeowners who had contracted with the appellee, Landmark Construction Group, to replace a hail-damaged roof. After the purchase, the new roof leaked, causing damage to the house. Landmark refused to address the leaks, arguing that any warranty given to the prior homeowners did not transfer to Fleig. Fleig sued Landmark, asserting theories of implied warranty, contractual warranty, and fraud.The case was initially heard by two trial judges and was appealed twice. The trial court granted Landmark's motion for a directed verdict and awarded Landmark $5,000 in attorney fees. Fleig appealed, and the Court of Civil Appeals affirmed the trial court. The Supreme Court of the State of Oklahoma vacated the Court of Civil Appeals opinion and remanded the matter to the trial court. After a second bench trial, the trial court entered an award against Landmark for $2,725. Fleig appealed again, and the Court of Civil Appeals affirmed the trial court in part, reversed it in part, and remanded the cause.The Supreme Court of the State of Oklahoma granted certiorari to address whether the trial court's order awarding attorney fees evidenced that the trial court complied with the directives of State ex rel. Burk v. City of Oklahoma City. The court held that it did not. The court found that the trial court order awarding attorney fees did not set forth with specificity the facts and computation to support the award. The court held that the trial court must make findings of fact incorporated into the record regarding the hours spent, reasonable hourly rates, and the value placed on additional factors. The court vacated the Court of Civil Appeals opinion in part, reversed the trial court in part, and remanded the cause for proceedings consistent with its opinion. View "Fleig v. Landmark Construction Group" on Justia Law

This case, decided by the Supreme Court of the State of Oklahoma, involved a dispute between the Governor of Oklahoma and the state's legislative leaders. The Governor sought a declaration that the legislative leaders did not have the authority to pass two bills related to Tribal compacts on behalf of the state.The case has its roots in previous US Supreme Court decisions that allowed Oklahoma to tax tobacco products sold on Indian lands to non-tribal members and to enter into agreements with tribal nations regarding these taxes. Following these decisions, Oklahoma's governor negotiated and entered into compacts with tribal nations regarding excise taxes on tobacco products and motor vehicle licensing and registration fees.The current dispute revolves around compacts negotiated in 2013. The Governor argued that the legislature lacked the authority to pass two bills extending the expiration of these compacts, alleging that the bills were the product of an unlawful concurrent special legislative session, that they violated the separation of powers by exercising powers that belong to the Executive branch, and that they contradicted his exclusive authority to negotiate state-tribal compacts.The court held that the legislature had the constitutional authority to consider the bills during a concurrent special session, and that the legislation did not exceed the call of the special session. The court also held that the Governor's authority to negotiate state-tribal compacts is statutory, not constitutional, and that the passage of the bills was not an infringement on the Governor's statutory authority to negotiate and enter into state-tribal compacts. Therefore, the court denied the Governor's request for declaratory relief. View "Stitt v. Treat" on Justia Law

Several school districts in Oklahoma launched a legal action claiming they had received insufficient State Aid payments for several years due to incorrect calculation by the Oklahoma State Department of Education. They sought to compel the Oklahoma State Board of Education to recover excessive State Aid payments made to other school districts and redirect them to the underfunded districts. The district court granted summary judgment in favor of the intervening school districts, stating that the State Board of Education had no duty to seek repayment of excessive State Aid payments until an audit approved by the State Auditor and Inspector was performed.The case was brought before the Supreme Court of the State of Oklahoma, which agreed with the lower court. However, the court raised the issue of the school districts' standing to compel legislative appropriations and remanded the case for adjudication of standing. Upon remand, the district court granted summary judgment to the appellees, concluding that the school districts failed to demonstrate that they initiated their action before the expiry of any State Aid appropriations from which they sought additional funds. The case was dismissed based on the school districts' lack of standing.On appeal, the Supreme Court of the State of Oklahoma affirmed the lower court's decision, holding that the school districts lacked a legally cognizable aggrieved interest and therefore didn't have standing. The court stated that the school districts sought funds that were previously appropriated and had now lapsed. Hence, the districts had no cause of action to obtain legislatively appropriated funds because those funds had expired by application of the Oklahoma Constitution. View "INDEPENDENT SCHOOL DISTRICT #52 OF OKLAHOMA COUNTY v. WALTERS" on Justia Law

In this case, the Supreme Court of the State of Oklahoma addressed a claim brought by a mother seeking recovery for the loss of her minor child who had drowned in a neighbor's swimming pool. The mother alleged negligence against the property owner, claiming that the swimming pool was an "attractive nuisance." Initially, the district court granted summary judgment in favor of the property owner, arguing that the owner did not owe a duty to the child. The mother appealed the decision, leading the Court of Civil Appeals to reverse the district court's judgment, positing that whether the swimming pool was an attractive nuisance was a fact for the jury to decide.Upon review, the Supreme Court of the State of Oklahoma held that the swimming pool was not an attractive nuisance as a matter of law. The court observed that the pool did not contain any hidden or unusual element of danger. However, the court also determined that a question of fact remained regarding whether the owner could be held liable under ordinary premises liability law. This conclusion barred summary judgment in favor of the property owner.Thus, while the Court affirmed the district court's judgment concerning the attractive nuisance claim, it reversed the decision on the issue of ordinary premises liability. The case was remanded for further proceedings consistent with the Supreme Court's opinion. It was noted that these circumstances would allow a jury to evaluate all surrounding facts in determining liability under ordinary premises liability law. View "Brown v. Dempster" on Justia Law