Justia Oklahoma Supreme Court Opinion Summaries

Plaintiff Stockbridge Energy, LLC brought suit against Jim Taylor, John Groninger, Jr., and Taylor Drilling Corp. in 2003, alleging, among other things, a breach of the parties' partnership and agreement for oil and gas lease development in Osage County. Specifically, Stockbridge alleged the defendants failed to account for the profits and losses of the partnership, failed to transfer property according to the parties' agreement, engaged in "secret transactions," and misappropriated profits due the partnership. The individuals, Jim Taylor and John Groninger, Jr., specially appeared and moved to dismiss for failure to state a claim on the grounds that the petition showed no individual liability on their part and that the theory of "piercing the corporate veil" was not viable under the facts as pled. Stockbridge did not respond to the motion of the individual defendants and, on August 17, 2004, an order was filed wherein the trial court granted the unopposed motions to dismiss. There was no discussion regarding any amendment of the petition nor did the trial court's order of dismissal set forth a time to allow any amendments. More than four years after the order granting the motions to dismiss, Stockbridge filed a motion seeking to amend its petition to add Taylor and Groninger back in as individual defendants. Over the objections of the defendants, the trial court granted leave to amend by no later than May 20, 2009. Stockbridge filed an amended petition re-naming Taylor and Groninger, and also added a new defendant, David Bomberger. Taylor and Groninger appealed the Court of Civil Appeals' judgment which agreed with the trial court in adding them back into the litigation after they had been dismissed years ago. The individual defendants argued to the Supreme Court that the time to amend the pleadings in this case, if any, should not have extended beyond the applicable statute of limitations or the one year savings clause to which a dismissed claim is otherwise subject. The Supreme Court agreed and reversed the appellate court's order. View "Stockbridge Energy, LLC v. Taylor" on Justia Law

The issue this case presented for the Oklahoma Supreme Court's review centered on a dispute between Defendants-Appellants The Board of County Commissioners of Canadian County and certain citizens and officers of Canadian County, over the legal usage of funds generated from a sales tax enacted by the voters of Canadian County in 1996. In response to concerns raised over the legality of using funds generated by the Tax to pay for juvenile programs and services, in addition to the physical structures, an Attorney General Opinion was requested. The Attorney General issued an opinion concerning the matter in 2014. The Attorney General examined the resolution in question, Resolution No. 96-20, and determined that the language did not authorize use of the Tax for the funding of programs, salaries and expenses related to operation of the juvenile bureau, or even certain aspects of the physical facilities. In the wake of the Opinion, the Board ceased using the Tax for funding the programs, services, and salaries deemed outside the purpose of the Tax, and instead sought other funding sources for those items. Plaintiffs filed suit against the Board in the District Court in late 2014, seeking declaratory relief, a temporary restraining order and temporary injunction pending a declaratory ruling, and a writ of mandamus by way of ancillary relief. In an order filed on January 28, 2015, the trial court granted Citizens' request for a temporary injunction, determining: (1) Citizens were likely to prevail in their request for a declaratory judgment; (2) the Board would not suffer irreparable harm if the temporary injunction was issued; and (3) Citizens would suffer irreparable harm if the temporary injunction was not issued. The Board appealed, arguing that Plaintiffs failed to meet their burden of proof for a temporary injunction. After examining the available evidence, the Supreme Court determined that that the trial court's issuance of a temporary injunction was not an abuse of discretion or against the clear weight of the evidence. Accordingly, the order of the trial court granting a temporary injunction was affirmed. View "Edwards v. Bd. of Cty. Commr's." on Justia Law

Petitioner Rodney Dutton sought an extraordinary writ at the Oklahoma Supreme Court to challenge his convictions in three criminal proceedings in the municipal court for The City of Midwest City. He also requested an alternative remedy that would compel the District Court to provide him with a new appeal of his convictions in the District Court. Dutton alleged that in 2013, he was convicted in the municipal court of the City of Midwest City on charges of assault, public intoxication, and domestic assault and battery, for which he received a thirty-day jail sentence. He stated that he filed three applications for post-conviction relief at the District Court after his release. The District Court dismissed the applications on grounds that they should have been filed with the municipal court in Midwest City. His application for the Supreme Court to assume original jurisdiction was filed approximately one year and three months after his release. Dutton's claims, construed liberally because of his pro se status, alleged numerous constitutional violations and procedural errors at the municipal and district courts that entitled him to the relief he sought. The Supreme Court assumed original jurisdiction for the sole purpose of determining its jurisdiction to review Petitioner's allegations. After review, the Court held that it did not possess jurisdiction to either review the merits of Petitioner's cause of action challenging his municipal criminal convictions or compel the District Court to provide him with a new direct appeal of those convictions to the District Court. Dutton failed to show that he lacked adequate remedies in either a municipal court or the District Court. Dutton's claims were criminal matters and the Supreme Court declined to assume original jurisdiction on his claims or grant him relief on them without prejudice to him presenting them, in the proper court. View "Dutton v. City of Midwest City" on Justia Law

On July 25, 2008, Jason Patterson died at the scene when the southbound motorcycle he was driving at highway speed impaled onto the front driver side windshield of Merrill's northbound vehicle after it crossed into Patterson's lane of traffic. Plaintiff Misty Fargo, a passenger on the motorcycle, was thrown from the motorcycle, receiving multiple injuries. Plaintiffs Fargo and Patterson's estate initially filed this action against Teresa Hays-Kuehn, Ginger Merrill and Angeline Sankey for negligence in the operation of their respective vehicles, but later filed a dismissal without prejudice against Merrill and Sankey. Kuehn was the only remaining defendant in this matter. Kuehn, whose vehicle did not collide with the motorcycle, moved for summary judgment asserting that even if her actions were negligent, at most they created a condition and were not the proximate cause of plaintiffs' damages thereby relieving her of liability. The trial court sustained the motion and plaintiffs appealed. The Court of Civil Appeals affirmed finding Kuehn's actions were not the proximate cause of Plaintiffs' injuries and damages. After review, the Supreme Court held that whether Kuehn's actions were the proximate cause of the accident or merely a "condition" was a question for the trier of fact, making summary judgment inappropriate. View "Fargo v. Hays-Kuehn" on Justia Law

Appellees operate wastewater injection wells in and around Lincoln County, Oklahoma, as well as other wells in central Oklahoma. Since approximately 2009, Oklahoma has experienced a dramatic increase in the frequency and severity of earthquakes. In 2011, Appellant Sandra Ladra was at home in Prague watching television in her living room with her family when a 5.0 magnitude earthquake struck nearby. Appellant's home began to shake, causing rock facing on the two-story fireplace and chimney to fall into the living room area. Some of the falling rocks struck Appellant and caused significant injury to her knees and legs, and she was rushed immediately to an emergency room for treatment. She claimed personal injury damages in excess of $75,000. Appellant filed this action in the District Court of Lincoln County to recover damages from Appellees, alleging that their injection wells were the proximate cause of Appellant's injuries. The district court dismissed the case, explaining that the Oklahoma Corporation Commission ("OCC") had exclusive jurisdiction over cases concerning oil and gas operations. Appellant filed Court a Petition in Error to the Supreme Court seeking review of the district court's order. The Supreme Court concluded after review that Appellant properly brought her case to the district court, and the district court erred in dismissing it. The case was remanded for further proceedings. View "Ladra v. New Dominion, LLC" on Justia Law

Both parties in this matter sought dissolution of their marriage on grounds of incompatibility. The wife informed the trial court that she was terminally ill and wanted to finalize the divorce before her death as she wished to leave her part of the estate to her daughters. The judge granted the parties the divorce, and filed a Court Minute memorializing his ruling. The judge signed and dated the Court Minute and the attorneys who represented the parties also signed. The judge included an order in the Court Minute for mediation to resolve property issues and further ordered that a journal entry be presented to the court within five days. However, the wife died before reaching a property settlement with the husband. No journal entry was filed. The husband filed a motion to dismiss on the grounds that after the wife died, the trial court lacked jurisdiction to proceed with the dissolution of marriage action. The wife's successors filed a response objecting to dismissal of the action. The trial court granted the husband's motion to dismiss. On appeal, the Court of Civil Appeals affirmed. The issue this case presented for the Supreme Court's review was whether, where both parties sought dissolution of their marriage, was effective at the time pronounced by the trial court even though property issues had not been settled and no journal entry had been filed. Although a judgment is generally not "enforceable in whole or in part unless or until it is signed by the court and filed," Oklahoma law carves out an exception for divorce proceedings, where the adjudication of any issue shall be "enforceable when pronounced by the court." The Court found that the husband did not oppose the dissolution of the marriage; what he opposed in essence was the bifurcation of the divorce between the dissolution of the marriage and the property settlement. The implications of this for proceedings in which a spouse dies before a journal entry is filed, was that a trial court may pronounce that the marriage is dissolved, effective immediately, but that decision is not appealable until it is filed. The district court erred in dismissing this case for lack of jurisdiction. The Supreme Court remanded for the trial court to divide the property and take such further actions as were necessary. View "Alexander v. Alexander" on Justia Law

The issue this case presented for the Oklahoma Supreme Court's review was whether the district court erred in sustaining a legal parent's motion to disqualify opposing counsel. More specifically, the question centered on whether the integrity of the judicial process was likely to suffer real harm when an attorney who represents a client in a proceeding to establish paternity and to determine custody of a minor child failed to report suspected child abuse to the proper authorities as required by statute, conducts a forensic interview of the child to obtain evidence to support the client's position, did not obtain the legal parent's permission prior to the interview, and filed his own affidavit attesting to the credibility of the child's affidavit. Brandy Poindexter (Mother) is the legal parent of a minor child (Child) born in 2005. On September 6, 2006, Michael Jensen (Client) filed a paternity action seeking joint custody of Child. William D. Thomas (Attorney) filed an entry of appearance on Client's behalf, becoming Client's fourth attorney in the paternity proceeding. The issue of paternity is not contested, but the district judge has yet to enter a final paternity decree. Child again alleged that he had been abused by Mother and her husband. This time, Client did not report the new allegations to DHS, but instead brought the Child to Attorney to be interviewed. On January 12, 2014, Attorney conducted a forensic interview of Child without seeking permission from Mother or securing independent counsel for Child. Only Attorney and Child were present during the interview. At a subsequent hearing on paternity, Mother moved to disqualify Attorney. Upon review, the Supreme Court concluded that the district court did not err in sustaining the motion to disqualify opposing counsel when the attorney likely compromised the legal parent's right to a fair proceeding by contaminating the fact-finding procedure and by establishing a relationship of undue influence with the child. View "Jensen v. Poindexter" on Justia Law

Kelly Jones was the biological mother of T.T.S. The State filed a petition seeking to adjudicate T.T.S. as a deprived child because the child "lacked 'appropriate parental care' and had been 'placed in threat of harm'" through mother's actions. Specifically, the state alleged the mother was a drug user and provided an unfit home environment for the child. In addition, the petition asserted that following a drug binge, mother was discovered by a law enforcement officer asleep with her boyfriend in a parking lot while T.T.S. slept nearby, unsupervised, in mother's car. Two windows had been broken on the vehicle and pieces of glass were located in T.T.S' child safety seat. The goal, according to the State's petition, was reunification of T.T.S. with mother. Throughout the pendency of this case, T.T.S. resided with foster parents. A subsequent Department of Human Services (DHS) progress report was filed with the trial court approximately a year later, and disclosed that mother had been arrested and was incarcerated in the Grayson County Jail in Sherman, Texas. A court minute filed after the review hearing suggested DHS intended to pursue termination of parental rights, which was ultimately granted. On appeal of the termination, mother challenged the trial court's failure to provide jurors with legally correct instructions and verdict forms. The Supreme Court reversed and remanded for a new trial, finding that the individualized service plan (ISP) contained an expansive list of remedial measures DHS desired mother to accomplish; some of the items were designated as mandatory, while others were characterized as desired. "What precisely was expected from mother in this case to re-establish physical custody of T.T.S. was less than clear." Moreover, the Court found that none of the State's applications to terminate mother's parental rights set forth the precise conditions mother failed to correct. Similarly, neither the jury instructions nor the verdict forms provided specificity with regard to the corrective measures mother had allegedly failed to ameliorate. Without this information mother could not effectively defend against the State's action to dissolve the parent-child relationship. "Due process requirements mandate reasonable notice of the conditions leading to a deprived adjudication, including jury instructions and verdict forms which outline a parent's purported noncompliance." View "In the matter of T.T.S." on Justia Law

The question presented on appeal to the Oklahoma Supreme Court in this case was whether an owner of real property received constitutionally sufficient notice of the sale of his property for delinquent taxes when notice was provided only by publication and certified mail that was returned undelivered. Appellant-landowner neglected to pay taxes on certain real property in McIntosh County. The property was sold at a tax sale and a tax deed was issued to the buyer. The landowner filed suit seeking to invalidate the tax deed and quiet title in himself, asserting that the sale and resultant deed were void because he was not given constitutionally sufficient notice of the sale and was denied his right to redeem the property. Both the landowner and the county defendants moved for summary judgment. The trial court granted the county defendants' motion and denied the landowners. The landowner appealed, and the Court of Civil Appeals affirmed. After review, the Supreme Court held: (1) that the landowner did not receive constitutionally sufficient notice; and (2) the sale and resultant tax deed were therefore void. View "Crownover v. Keel" on Justia Law

Plaintiff Alan Benefiel and Christa Benefiel were divorced by a consent decree entered in 2005. Consistent with the terms of the parties' divorce decree, Plaintiff executed a quit claim deed, transferring title in the former marital residence to Christa. In exchange for relinquishing his ownership interest in the property, the decree required Christa to pay Plaintiff $25,000.00 as alimony in lieu of property division. Payments were structured incrementally over a period of four years; $10,000 was due in 2005, and $5,000 was payable on January 31 for years 2006, 2007, and 2008. As security for the property division judgment, Plaintiff was awarded a lien encumbering the residence. The lien was to remain in effect until all payments were completed. Further, the decree contained a clause which vested Plaintiff with the right to immediate title and possession of the property should Christa fail to timely remit any of the annual installments Prior to paying the final installment, Christa sold the subject real property to a third-party, Jewel Boulton. Boulton paid $17,000.00 as a down payment and financed the remainder of the purchase price. Though the divorce decree had not been filed with the local county clerk, it was made a part of the abstract of title. Despite its inclusion in the abstract, a title opinion issued prior to closing failed to identify the divorce judgment as a potential cloud or defect. Christa failed to make the final property division installment due on January 31, 2008. Plaintiff filed suit against both Boulton and Christa, asserting several claims, including demands to quiet title and to allow foreclosure of the lien. In her Answer, Boulton maintained that Plaintiff had no right, title, or interest in the house and that his lien from the divorce decree was ineffective and void. Both Boulton and Plaintiff sought summary judgment. The trial court entered judgment in favor of Plaintiff, finding: (1) the divorce decree created a valid "mortgage lien" against the property; (2) Christa defaulted on the property division obligation; and (3) in accordance with the divorce decree, Christa's default resulted in the automatic reversion of title to Plaintiff. In a prior appeal, the Court of Civil Appeals invalidated the reversionary clause, but found the property was subject to a valid lien. On remand, Boulton invoked her statutory right of redemption, under 42 O.S. 20, by paying the underlying obligation plus interest; however, Boulton's discharge of the lien was not accomplished for more than three years after litigation was commenced. Thus, Plaintiff was the prevailing party on the lien foreclosure claim. After its review, the Supreme Court held that Boulton's redemption of the subject property occurred when she tendered both the underlying $5,000.00 obligation and the accumulated interest owed thereon. The Court of Appeals' opinion was thus vacated, and the case remanded for further proceedings. View "Benefiel v. Boulton" on Justia Law