Justia Oklahoma Supreme Court Opinion Summaries

Plaintiff-Appellant Mastercraft Floor Covering, filed a lawsuit against Charlotte Flooring (CFI), a North Carolina corporation, in Oklahoma. Mastercraft alleged that CFI had hired it to install carpet in a North Carolina casino, but that after the work was completed, CFI failed to pay for the labor, services, and materials. CFI entered a special entry of appearance to object to Oklahoma having jurisdiction to decide the cause because CFI lacked the requisite minimum contacts to be sued in the State of Oklahoma. The trial judge, determined that Mastercraft failed to prove that CFI had sufficient minimum contacts to permit Oklahoma to exercise jurisdiction over CFI without offending conventional notions of fair play and substantial justice. Mastercraft appealed, and the Court of Civil Appeals affirmed. Upon review, the Supreme Court concluded that because of the totality of contacts with the Oklahoma-based corporation, the trial court had personal jurisdiction. View "Mastercraft Floor Covering, Inc. v. Charlotte Flooring, Inc." on Justia Law

An Oklahoma worker was killed at Employer's jobsite in Texas. The employer's insurer paid the worker's Widow death benefits provided by Texas workers' compensation law. The widow also recovered damages in a wrongful death tort action in Texas. When the Insurer sought subrogation from the widow's wrongful death damages as allowed by Texas law, she filed suit in Oklahoma to prevent subrogation. She sought a declaratory judgment that the rights of Oklahoma workers and their dependents were governed by Oklahoma's Workers' Compensation Act, notwithstanding the worker's injury or death in another state, and any benefits that may be paid under another state's workers' compensation law. In particular, Widow asked the Oklahoma court to enforce the provision in Oklahoma law that forbids subrogation in cases of death benefits. The trial court granted the declaratory relief sought by the widow. On appeal by the Insurer, the Court of Civil Appeals reversed. The Court of Civil Appeals ruled that the widow had to commence a proceeding by filing a claim with Oklahoma's Workers' Compensation Court before Oklahoma could exercise jurisdiction over the benefits due the widow, including enforcement of the anti-subrogation provision in death benefit cases. Because she never filed a claim with Oklahoma's Workers' Compensation Court, the Court of Civil Appeals held subrogation was proper. Upon review, the Supreme Court affirmed the trial court's judgment and vacated the appellate court in this case. View "Holley v. ACE American Ins. Co." on Justia Law

The issue presented to the Supreme Court in this case was whether the district court erred in proceeding in the underlying foreclosure suit after the defendant filed a motion giving notice of the plaintiff corporation's suspension in June of 2000 for failure to pay corporate franchise taxes; for the eleven months that the plaintiff was on notice that its suspension was an issue in the suit, the corporation failed to be reinstated; and title 68, section 1212(C) of the Oklahoma Statutes denies a suspended corporation the right to sue or defend. Upon careful consideration, the Supreme Court held that the district court did err in proceeding; the Court therefore issued a writ of mandamus to direct the district court to vacate all orders previously entered. View "Moncrieff-Yeates v. Kane" on Justia Law

The issue on appeal to the Supreme Court centered on whether Lincoln Farm, L. L. C. breached a contract to sell potatoes to Farming Technology Corporation, and whether certain provisions of the Uniform Commercial Code involving the unavailability of a carrier and a commercially impracticable method of delivery were applicable to the parties. Farming Technology argued at trial that Lincoln Farm was required to build a private rail spur in order to fulfill Lincoln Farm's contractual obligation to load potatoes on railcars or trucks furnished by Farming Technology Corporation to take delivery of the potatoes. After review of the contract in question, the Supreme Court held that the contract unambiguously stated that Farming Technology Corporation would furnish railcars or trucks to take delivery of the potatoes, and that the contract did not state that Farming Technology had the right to insist on delivery solely by rail, or to insist that Lincoln Farm build a private rail spur. View "Lincoln Farm, LLC v. Oppliger" on Justia Law

Appellant filed a Motion to Override Risk Level Classification under the Sex Offenders Registration Act (SORA). The trial court ruled it did not have jurisdiction to grant the relief requested. The trial court record did not reflect when appellant was first required to register, but he began actual registration in the summer of 2007. Following appellant's initial registration, the State of Oklahoma ex rel. Oklahoma Department of Corrections, notified appellant that he had been assigned a numeric risk level of three and would thereafter have to register for life. Appellant claimed that prior to this determination of a level assignment he was only required to register for ten years. Appellant filed a Motion to Override Risk Level Classification and Brief in Support in 2009. Less than two weeks after appellant filed his motion, new amendments to SORA took effect. In light of the amendments, the trial court ruled it lacked jurisdiction to grant appellant relief. Upon review, the Supreme Court concluded that the Department could not retroactively increase his registration period. As such the trial court had jurisdiction over appellant's case. The matter was reversed and remanded for further proceedings. View "Burk v. Oklahoma" on Justia Law

A student athlete asked for a permanent injunction against the Oklahoma Secondary School Activities Association (OSSAA) to block it from enforcing its sanctions against the athlete following its determination that the student athlete, school, and others violated the OSSAA's rules and policies. The athlete appealed, challenging the applicable standard of review and alleging that the OSSAA's actions were arbitrary and capricious. In 2012, the OSSAA received a copy of a newspaper article concerning the school's successes attracting the attention of college football recruiters. Based on comments made in the article, the OSSAA became concerned that the school might have violated what the OSSAA considered to be its long-standing prohibition on member schools paying for their student-athletes to attend individual athletic camps. The OSSAA notified the school of its concerns and asked for confirmation as to whether it had paid for selected students to attend individual camps. The OSSAA alleges it received no response prior. Upon review, the Supreme Court concluded the trial court applied the incorrect standard of review, and that under any standard, the OSSAA's actions were arbitrary and capricious. View "Scott v. Oklahoma Secondary School Activities Ass'n" on Justia Law

First American Cash Advance, owned by Valued Services, L.L.C. was robbed twice. The first robbery occurred on New Year's Eve 2008, and the second was in the spring of 2009. Respondent-Claimant Leslie Tregenza was the branch manager and the only employee on the premises during both robberies. A man wearing something covering his face and a ball cap committed the first robbery; in the second, two men stole all of the cash on hand in the office. These men did not have guns. However, one of the robbers threw an empty plastic cash drawer at respondent's head. She did not return to work for her employer after the second robbery. Claimant filed her Form 3 in October 2009, alleging an accidental injury arising out of and in the course of her employment. She alleged she sustained an injury to her head with psychological overlay in the form of post-traumatic stress disorder (PTSD) and PTSD headaches. She sought permanent total disability (PTD) as a result of her injuries, claiming she was unable to work or to be out in public. The trial the court concluded respondent was permanently totally disabled and awarded her continuing medical maintenance in the nature of four annual office visits and prescription medication. The employer appealed the trial court's holding and the appellate court reversed. After its review, the Supreme Court concluded the Workers' Compensation Court received competent evidence that Claimant was permanently totally disabled. The Court vacated the appellate court's decision and affirmed the order of the lower court. View "Valued Services, LLC v. Tregenza" on Justia Law

Charles Sheffer, Jennifer Sheffer, and their minor son, J.S., were injured when their tractor trailer collided with a rental vehicle leased to William Garris and driven by David Billups, employees of Carolina Forge Company, L.L.C. Plaintiffs sued Carolina Forge on theories of respondeat superior and negligent entrustment. They also sued the Buffalo Run Casino, the Peoria Tribe of Indians of Oklahoma, and PTE, Inc. for dram-shop liability. The trial court granted summary judgment in favor of Carolina Forge, finding as a matter of law Carolina Forge was not liable for its employees' actions under a theory of respondeat superior and did not negligently entrust the rental vehicle to its employees. The trial court also dismissed, sua sponte, the Buffalo Run Casino, PTE, Inc., and the Peoria Tribe of Indians of Oklahoma, determining that injunctions issued by the Western District of Oklahoma prohibited suit for any tort claims against a tribe or a tribal entity. Plaintiffs appealed both orders. Upon review, the Supreme Court concluded the Peoria Tribe was immune from suit in state court for compact-based tort claims because Oklahoma state courts are not courts of competent jurisdiction as the term is used in the model gaming compact. Furthermore, the Court found that because Congress has not expressly abrogated tribal immunity from private, state court dram-shop claims and because the Peoria Tribe and its entities did not expressly waive their sovereign immunity by applying for and receiving a liquor license from the State, the tribe was immune from dram-shop liability in state court. View "Sheffer v. Buffalo Run Casino" on Justia Law

Plaintiff Joseph W. Hendricks challenged the constitutionality of the Sex Offenders Registration Act ("SORA") and its enforcement. Upon review, the Supreme Court held that applying SORA's requirements to sex offenders now residing in Oklahoma who were convicted in another jurisdiction prior to SORA's enactment but not applying the same requirements to a person convicted in Oklahoma of a similar offense prior to SORA's enactment, violates a person's equal protection guarantees. View "Hendricks v. Jones" on Justia Law

Plaintiff Michael Bollin challenged the constitutionality of the Sex Offenders Registration Act (SORA) and its enforcement. Upon review, the Supreme Court found that when Bollin entered Oklahoma in June 2004, the law did not require a person with a pre-SORA conviction in another jurisdiction to register. Therefore, Bollin should have been held to the law in effect at the time he entered Oklahoma and became subject to SORA. Therefore, Bollin was not required to register under SORA. View "Bollin v. Jones" on Justia Law