Justia Oklahoma Supreme Court Opinion Summaries

Stephens Production Company sought to condemn underground natural gas storage easements and surface easements to complete an underground natural gas storage facility on and underneath approximately 900 acres of mostly rural property in Haskell County. Approximately 140 Defendants were named in the Petition. Stephens Production had previously offered such Defendants "just market value" for their respective interests, but the Defendants refused the offers. The trial court appointed three commissioners to value just compensation due for each Defendant listed in the Petition. All Defendants except one, appellant Royce Larsen, settled with Stephens Production. The Commissioners valued Larsen's property taken and the damage to the remainder at $12,400.00. Larsen objected to this amount, and his case proceeded to trial. Larsen's expert testified the just compensation value was approximately $419,000.00; Stephens Production's expert valued the just compensation at $9,000.00. The trial court determined that just compensation for the property was $9,000.00. Without any evidence from Larsen regarding the reasonable probability of combination or the market demand for underground gas storage in the area, the highest and best use of the property was the use to which it was subject at the time of the taking - natural resource, agricultural, and recreational use. The Supreme Court concluded the record supported the trial court's valuation of just compensation at $9,000.00. View "Stephens Production Co. v. Larsen" on Justia Law

Shonda Brisco entered into an employment agreement with Oklahoma State University, which provided that she would be reappointed contingent on her job performance. She was not reappointed and successfully brought suit for breach of contract. After trial, the district court awarded Brisco attorney fees under 12 O.S. 2011 section 936. The State appealed the award of fees, and the Court of Civil Appeals affirmed. The Supreme Court granted certiorari to address whether fees were authorized under 12 O.S. 2011 section 936, and held they were not. View "Brisco v. Oklahoma ex rel Bd. of Regents Agricultural & Mechanical Colleges" on Justia Law

Appellant Jennifer Boatman, now Walls (Mother), and Appellee Nick Boatman (Father) married in 2004. They have a single child, a daughter, born in 2005. The parties divorced in 2007, and equally shared time with their daughter under a joint custody plan. In 2013, Mother filed a Notice of Intent to relocate with the child, and Father objected. The trial court denied Mother's application to relocate, concluding that the proposed relocation was not made in good faith and not in the best interest of the child. It also ordered each party to pay their own attorney fees. Mother appealed both judgments in separate companion cases, and both were affirmed by the Court of Civil Appeals. The Supreme Court held that before a joint custodian can invoke the relocation provisions, the court must determine a primary physical custodian. The Court also held that the trial court did not err in directing that each party pay their own fees. View "Boatman v. Boatman" on Justia Law

R.V. Bebout died testate on March 30, 1980, as a resident of Tarrant County, Texas. His Last Will and Testament, dated March 8, 1977, was admitted in the Probate Court of Tarrant County, Texas. At the time of his death, Bebout owned mineral interests in Canadian County, Oklahoma. On September 30, 1981, an ancillary Petition for Probate of Foreign Will was filed in the District Court of Canadian County. Bebout's will provided that his estate was to be distributed in trust to his wife, if she survived him. In the event his wife predeceased him, which she did, his will provided that one-half of his estate was to be distributed to his daughter, Betty Ewell, and one-half to his granddaughter, Betsy Kuykendall. The will made no mention of Bebout's son, Russell Bebout, who had predeceased him, or Bebout's grandsons, John Bebout and James Bebout (Grandsons). The Final Order in the Estate of R.V. Bebout, filed in 1982, distributed his mineral interests to his daughter and granddaughter in equal shares pursuant to the terms of his will. In 2014, the grandsons filed this action in Canadian County, alleging that the mineral interest distribution was void to the extent it failed to distribute the mineral interests one-quarter each to his grandsons who were pretermitted heirs under the will. Citing the Oklahoma Supreme Court's decision in “Booth v. McKnight,” (70 P.3d 855 (2003)), the District Court agreed with the grandsons and found the Final Order issued in 1982 was void on its face for lack of proper notice to the grandsons. The Court of Civil Appeals affirmed. After review, the Supreme Court concluded that notice to the grandsons was constitutionally sufficient, and thus, the Final Order was not void for lack of proper notice. Grandsons' challenge to the Final Order more than thirty years later was deemed untimely. View "Bebout v. Ewell" on Justia Law

A delay of approximately sixteen months occurred between the arrest of the plaintiff-appellee Nathan Nichols, Jr. for driving under the influence and the administrative hearing resulting in revocation of his driver's license. Certiorari was granted to address a single issue: whether the delay constituted a violation of the constitutional right to a speedy trial guaranteed by the Oklahoma Constitution Article 2, Section 6.1. The trial court set aside the revocation order and reinstated Nichols' driving privileges. The Court of Civil Appeals reversed. Other than funding and personnel constraints, the Department presented no viable reason for the delay. Under the facts of this case, the Supreme Court held that the driver's right to a speedy hearing was violated, and ordered reinstatement of his driving privileges. View "Nichols v. Oklahoma ex. rel. Dept. of Public Safety" on Justia Law

Employee-appellant Tracy Meeks sued an insurer for bad faith refusal to timely comply with several orders of the Workers' Compensation Court awarding employee temporary total disability benefits after the insurer, without good cause, withheld employee's benefits on twenty-six separate occasions. Insurer moved for dismissal, asserting employee failed to obtain a certification order from the Workers' Compensation Court (a jurisdictional prerequisite for commencing a bad-faith action in district court). The District Court granted insurer's motion, but the Supreme Court reversed. Because the certification requirements were met here, employee was free to proceed in district court on his bad-faith claim against insurer for insurer's alleged bad faith refusal to provide temporary total disability benefits as ordered by the WCC. View "Meeks v. Guarantee Insurance Co." on Justia Law

The question presented to the Oklahoma Supreme Court by this case was whether the district court abused its discretion when it denied Appellant's (Biological Mother) second motion for reconsideration. In 2013, the district court terminated Biological Mother's parental rights to K.S. In 2015, Biological Mother filed a petition for guardianship over Child in Oklahoma County District Court. The district court denied the petition for guardianship without prejudice. The court noted Biological Mother's failure to serve or notify the proper parties and inability to do so in the future due to the confidentiality of adoption proceedings. The same day, Biological Mother filed a motion for reconsideration of the petition for guardianship and a motion asking the court to grant time to provide notice. The district court denied the motions for reconsideration and to grant time. The court noted that the motions were incoherent and stated that the court felt the petition contained circumstances such that the motions should be decided without a hearing under Rule 4(h) of the Rules for District Courts of Oklahoma. After review, the Supreme Court affirmed the district court's ruling, finding the district court was correct that notifying Parents of the guardianship proceeding was “an insurmountable hurdle” to Biological Mother and that it was allowed to deny the motion without a hearing. There was no abuse of discretion. View "In the matter of K.S." on Justia Law

Appellant John Doe filed suit against Appellees, a church and its minister, alleging torts and breach of contract after he was baptized and notice of his baptism was published on the internet, resulting in his alleged kidnapping and torture by extremists while travelling in Syria. The trial court sustained Appellees' motion to dismiss for lack of subject matter jurisdiction. Appellant appealed. The question presented for the Oklahoma Supreme Court’s review was whether the church autonomy doctrine, rooted in the First Amendment to the United States Constitution, barred the courts from considering Appellant’s claims against Defendants-Appellees. The Supreme Court held that it does. View "Doe v. First Presbyterian Church U.S.A. of Tulsa" on Justia Law

Petitioner Rodney Stanley Brown was employed by Respondent Claims Management Resources (CMR) as a claims adjuster. Brown suffered personal injury to his left knee. At the time Brown was injured, he finished his workday, clocked out, was leaving the office for the day when he fell while descending an interior stairwell. Brown's work area was on the second floor of the building where he worked, and CMR occupied the entire floor. Brown was unable to conclusively identify any factor that might have caused his fall. While admitting an injury occurred, CMR asserted Brown's injury was not compensable within the meaning of the Administrative Workers' Compensation Act (AWCA). A hearing on the matter was held before the Administrative Law Judge, and after considering the parties' stipulations, evidence, and arguments, the Administrative Law Judge concluded that Brown had failed to meet his burden of proving by a preponderance of the evidence that he suffered a compensable injury within the meaning of the AWCA. The Supreme Court concluded after its review that Brown was acting in the course and scope of his employment, and his injury was a compensable injury. The Workers' Compensation Commission’s interpretation of 85A O.S. Supp. 2013 sections 2(9) & (13) was legally incorrect and its order denying compensability was clearly erroneous in view of the competent evidence presented. Because relief was available on alternative grounds, the Court did not reach the constitutional issues presented. View "Brown v. Claims Management Resources, Inc." on Justia Law

Defendant Century Surety Company (Century) issued a Commercial Lines Policy to Plaintiff Siloam Springs Hotel, L.L.C. (Siloam). This policy included general liability insurance coverage of Siloam's hotel in Siloam Springs, Arkansas, for the policy period from November 13, 2012, through November 13, 2013. The insuring agreement of the general liability coverage form provided that Century would pay sums the insured was legally obligated to pay as damages because of bodily injury to which the insurance applies and that Century would have the right and duty to defend the insured against any suit seeking such damages. On January 17, 2013, several guests inside of the hotel allegedly suffered bodily injury due to carbon monoxide poisoning. The carbon monoxide allegedly escaped into the air due to leakage from the hotel's indoor swimming pool heater. Siloam sought coverage under its policy from Century, which Century denied based on an Indoor Air Exclusion at issue. The United States District Court for the Western District of Oklahoma certified a single question of Oklahoma law to the Oklahoma Supreme Court under the Revised Uniform Certification of Questions of Law Act, 20 O.S. 2011 sections 1601-1611: “Does the public policy of the State of Oklahoma prohibit enforcement of the Indoor Air Exclusion, which provides that the insurance afforded by the policy does not apply to ‘Bodily injury', 'property damage', or 'personal and advertising injury' arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause?” The Oklahoma Supreme Court answered the question in the negative. View "Siloam Springs Hotel, LLC v. Century Surety Co." on Justia Law