Justia Oklahoma Supreme Court Opinion Summaries

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

The Oklahoma County Criminal Justice Authority (OCCJA) filed a petition in the District Court of Oklahoma County seeking a writ of mandamus and an injunction against the Oklahoma State Department of Health (OSDH) to prevent unannounced jail inspections and an administrative proceeding based on an Administrative Compliance Order. The OCCJA argued that the OSDH exceeded its authority by demanding unannounced access for inspections and issuing compliance orders sooner than the statutory 60-day correction period. The OCCJA also contended that the statutes and administrative rules did not authorize unannounced inspections and that such inspections were unreasonable due to staffing and safety concerns.The District Court for Oklahoma County, presided over by Judge C. Brent Dishman, granted the OSDH's motion to dismiss in part, finding that the OSDH had statutory authority to perform unannounced inspections. The OCCJA appealed this decision. Concurrently, the OSDH filed an application in the Supreme Court of Oklahoma to assume original jurisdiction and sought a writ of mandamus/prohibition and declaratory relief against the OCCJA. The Supreme Court denied the OSDH's application to assume original jurisdiction in No. 122,524 and recast the OCCJA's appeal in No. 122,775 into an application to assume original jurisdiction and petition for a writ of prohibition.The Supreme Court of Oklahoma assumed original jurisdiction in No. 122,775 on the single issue of whether the OSDH has the authority to perform unannounced jail inspections. The Court concluded that the OSDH does have such authority, as unannounced inspections are a reasonable means to ensure compliance with legislative jail standards. The Court found that the District Court's interlocutory order was not contrary to law or an abuse of discretion and denied the OCCJA's petition for a writ of prohibition. View "Oklahoma State Department of Health v Oklahoma County Criminal Justice Authority" on Justia Law

Treyton Bailey was stopped for a traffic violation and subsequently arrested for suspicion of DUI after officers observed signs of impairment. Although Bailey consented to a blood test, the result was excluded due to a discrepancy in the chain of custody. Despite the lack of a valid test result, Service Oklahoma revoked Bailey's license. Bailey argued that Service Oklahoma lacked statutory authority to mail the revocation notice by regular mail, that revocation is invalid absent a certificate or affidavit of mailing even where the licensee received and acted upon the notice, and that revocation cannot be sustained without a valid test result when the driver did not refuse testing.The district court rejected Bailey's arguments, finding that Section 2-116 applies to Service Oklahoma and authorizes the agency to serve revocation notice by regular mail. The court also found that the State's proof of service was admissible and sufficient to establish adequate proof that notice was properly served. Additionally, the court determined that despite the exclusion of the blood result, the State met its burden of proof based on other competent evidence. The district court entered a Final Order Sustaining Revocation, which Bailey appealed.The Supreme Court of the State of Oklahoma affirmed the district court's order. The court held that Service Oklahoma is authorized to provide revocation notice by regular mail under Title 47, Section 2-116, and that this interpretation is necessary to preserve the coherence of the statutory scheme following the Legislature's transfer of authority to Service Oklahoma. The court also held that Bailey's due process challenge failed, as the record reflected that he received written notice of the revocation and acted upon it by filing a petition for judicial review. Finally, the court held that the district court properly sustained the revocation of Bailey's license based on the officer's sworn report and other competent evidence, despite the exclusion of the blood test result. View "Bailey v State of Oklahoma ex rel. Service Oklahoma" on Justia Law

William D. Lunn, individually and as the representative of the estates of his three deceased children, filed a wrongful death lawsuit against Continental Motors, Inc. (CMI) in October 2009, alleging a design defect caused an airplane crash that killed his children. In September 2012, CMI made an unapportioned offer of judgment for $300,000, which Lunn rejected. After a lengthy litigation process, a jury found in favor of CMI. Lunn moved for a new trial, which the district court granted in February 2021. CMI appealed, arguing the claims were barred by the statute of repose under the General Aviation Revitalization Act. The Court of Civil Appeals (COCA) reversed the district court's decision.CMI then sought attorney's fees, claiming entitlement under the offer of judgment statute since the judgment was less than their offer. The district court denied the motion, ruling the unapportioned offer invalid. CMI appealed this decision. COCA affirmed the district court's ruling, referencing prior cases that required offers of judgment to be apportioned among plaintiffs to be valid.The Supreme Court of the State of Oklahoma reviewed the case to address whether an offer of judgment under 12 O.S.2021, § 1101.1(A) must be apportioned among multiple plaintiffs. The court held that such offers must indeed be apportioned to allow each plaintiff to independently evaluate the settlement offer. The court emphasized that unapportioned offers create confusion and hinder the plaintiffs' ability to assess the offer's value relative to their claims. Consequently, the court vacated COCA's opinion and affirmed the district court's judgment, ruling CMI's unapportioned offer invalid. View "Lunn v. Continental Motors, Inc." on Justia Law

Christopher Couch was stopped by an Oklahoma Highway Patrol trooper for a tag light violation. The trooper observed signs of intoxication, including bloodshot eyes and the smell of alcohol, and administered field sobriety tests, which Couch failed. Couch agreed to a breath test, but due to errors, the test results were invalid. Despite the invalid test, Service Oklahoma revoked Couch's driver's license.The district court upheld the revocation, and the Court of Civil Appeals, Division III, affirmed this decision. However, Division IV of the Court of Civil Appeals had previously ruled in a separate case that revocation could not stand without a valid test result. Couch appealed, arguing that his revocation should be reversed based on Division IV's ruling and the relevant statutes requiring a valid test for revocation.The Supreme Court of the State of Oklahoma reviewed the case to resolve the conflict between the appellate divisions. The court held that a driver's license could be revoked based on an officer's sworn report establishing reasonable grounds for believing the driver was under the influence, even if the chemical test results were invalid. The court found that the officer's observations and Couch's performance on the field sobriety tests provided sufficient evidence to support the revocation. The court vacated the Court of Civil Appeals' opinion and affirmed the district court's order, upholding the revocation of Couch's driver's license. View "COUCH v STATEOF OKLAHOMA ex rel. DEPT. OF PUBLIC SAFETY" on Justia Law

The State of Oklahoma moved to terminate a mother's parental rights due to her methamphetamine addiction and failure to provide a stable environment for her child. The child was placed in emergency custody in May 2022, and the mother entered and left multiple inpatient treatment programs without completing them. The State filed a motion to terminate her parental rights in April 2023, and a jury trial was set for August 2023. The mother failed to appear for the trial, and her attorney requested a continuance, which was denied. The trial court held a nonjury trial and terminated her parental rights.The mother appealed the decision, and the Court of Civil Appeals, Division III, affirmed the trial court's ruling. The mother argued that the statute allowing the trial court to deem her failure to appear as a waiver of her right to a jury trial was unconstitutional. The Court of Civil Appeals did not substantively address this constitutional claim.The Supreme Court of the State of Oklahoma reviewed the case and found that the statute in question is constitutional. However, the court emphasized that due process requires that the record must reflect that the parent received notice of the possible consequences of failing to appear for the jury trial. The court vacated the Court of Civil Appeals' opinion and remanded the case to the trial court for an evidentiary hearing to determine whether the mother had received sufficient notice. The trial court is to hold the hearing within 30 days and submit findings of fact and conclusions of law to the Supreme Court within 15 days after the hearing. View "IN THE MATTER OF FB v STATE OF OKLAHOMA" on Justia Law

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