Justia Civil Procedure Opinion Summaries

In August 2014, a train operated by BNSF Railway Company collided with a pickup truck driven by Paul Watson at a railroad crossing in Pawnee County, Oklahoma. Watson, who was not wearing a seatbelt, died instantly, while his wife Terri and their minor child, both belted, survived with injuries. Terri Watson, on behalf of herself, her child, and as a representative of her deceased husband's estate, filed a wrongful death and personal injury lawsuit against BNSF, alleging negligent maintenance of the crossing and failure to install adequate safety features.The case went to trial, and after three weeks of testimony and evidence, the jury found in favor of BNSF on all claims. The plaintiffs' motion for a new trial was denied by the trial court. On appeal, the Court of Civil Appeals, Division IV, found prejudicial errors in the jury instructions, specifically noting that the instructions were biased in favor of BNSF and required an excessive degree of care from Watson. The appellate court reversed the trial court's decision and remanded the case for a new trial.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The court found that the jury instructions, when considered as a whole, were not so prejudicial as to mislead the jury. The court noted that the instructions accurately reflected Oklahoma law and did not impose a higher standard of care on Watson than required. Consequently, the Supreme Court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's judgment, and reinstated the jury's verdict in favor of BNSF. The case was remanded for further proceedings consistent with this opinion. View "WATSON v. BNSF RAILWAY COMPANY" on Justia Law

Kiefer Production Company (KPC), a non-party, appealed adverse discovery orders related to a subpoena duces tecum issued by the Keetons, co-trustees and co-personal representatives of Noma Rongey's estate. The Court of Civil Appeals (COCA) dismissed the appeal, stating the orders were not appealable. KPC then petitioned for certiorari, which was granted by the Supreme Court of Oklahoma.The district court had previously denied the Owners' motion to quash the subpoena and ordered KPC to produce financial documents to determine the value of Rongey's interest in KPC. The district court also placed Rongey's interest in pay status. COCA partially affirmed the district court's order but remanded the case to address the implications of Rongey's death and the scope of the documents requested. On remand, the district court denied KPC's renewed motion to quash and granted the Keetons' motion to compel the production of documents.The Supreme Court of Oklahoma held that the discovery orders were appealable and that the district court did not abuse its discretion in ordering KPC to produce the documents. The court found that KPC, as a non-party, had a substantial right affected by the orders and that the orders conclusively determined the issue of document production. The court also held that KPC's financial documents, including tax returns, were relevant to determining the value of Rongey's interest in KPC and were therefore discoverable.The Supreme Court vacated COCA's opinion and affirmed the district court's judgment, requiring KPC to comply with the subpoena. The court also held that KPC did not have standing to appeal the order placing Rongey's interest in pay status, as this issue was not final and was subject to further proceedings. View "ROYAL HOT SHOT INVESTMENTS v. KIEFER PRODUCTION CO." on Justia Law

Mark Glen Spencer died from sepsis two days after a surgical procedure performed by Dr. Lana Nelson at Norman Regional Medical Authority. Spencer's brother, Jimmy Wayne Spencer, acting as the Special Administrator of the estate, filed a wrongful death action against the hospital and Dr. Nelson, alleging negligent and grossly negligent treatment. The hospital delayed providing complete medical records, which were essential for evaluating the claim.The District Court dismissed the case, finding that the plaintiff had actual knowledge of the potential claim before the statutory deadline and that Dr. Nelson, as a hospital employee, was immune from individual liability under the Oklahoma Governmental Tort Claims Act (GTCA). The Court of Civil Appeals affirmed the dismissal, holding that the discovery rule did not apply to wrongful death claims under the GTCA and that Dr. Nelson could not be individually sued for actions within the scope of her employment.The Supreme Court of the State of Oklahoma reviewed the case and vacated the Court of Civil Appeals' opinion. The Supreme Court held that the discovery rule applies to wrongful death actions arising from medical negligence under the GTCA. It also ruled that governmental employees have no immunity under the GTCA for gross negligence or acts outside the scope of employment. The court found that the trial court erred in making factual determinations on a motion to dismiss and that it should have taken the plaintiff's allegations as true. The case was remanded for further proceedings consistent with these findings. View "SPENCER v. NELSON" on Justia Law

A group of medical providers sued a former employee for breach of an employment agreement. The employee counterclaimed, alleging he was owed unpaid wages and bonuses. The providers initially raised "failure to state a claim" as their sole affirmative defense. However, after nearly four years of litigation, they attempted to argue for the first time that the contract was illegal and therefore void. The lower court found that the providers had waived this affirmative defense and issued a judgment in favor of the employee. The providers appealed, and the Court of Civil Appeals reversed, concluding that the lower court had abused its discretion by refusing to consider the providers' claim of illegality.The Supreme Court of the State of Oklahoma disagreed with the Court of Civil Appeals. It held that the trial judge did not abuse her discretion in striking the providers' last-minute effort to raise a new affirmative defense. The court noted that the providers had failed to raise the illegality defense in their initial responsive pleading and did not seek to amend their answer in a timely manner. Furthermore, the providers did not raise the illegality defense until after the trial court had already awarded summary judgment to the employee on the issue of breach of contract, more than ten months after the close of discovery, more than nine months after the lower court's deadline for filing dispositive motions, and almost four years after the original lawsuit was filed. The court concluded that the record was sufficient to support a finding that the providers' delay was unjustified and prejudicial. The court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's order striking the illegality affirmative defense, and remanded the case to the Court of Civil Appeals to resolve any remaining undecided issues raised in the appeal. View "Tulsa Ambulatory Procedure Center v. Olmstead" on Justia Law

Survivors of the 1921 Tulsa Race Massacre and representatives of the estate of a deceased survivor filed a lawsuit against the City of Tulsa, the Tulsa Regional Chamber, the Board of County Commissioners for Tulsa County, the Sheriff of Tulsa County, and the Oklahoma Military Department. The plaintiffs alleged that the defendants' actions and omissions, beginning with the massacre and continuing to the present day, constituted a public nuisance. They also claimed that the defendants had unjustly enriched themselves by exploiting the massacre for their own economic and political gain.The District Court of Tulsa County dismissed the plaintiffs' claims. It found that the plaintiffs had failed to state a justiciable public nuisance claim and had not proposed a legally cognizable abatement remedy. The court also dismissed the unjust enrichment claim, citing a failure to correct a defective pleading.The plaintiffs appealed to the Supreme Court of the State of Oklahoma. They argued that the district court had erred in dismissing both their public nuisance and unjust enrichment claims. The Supreme Court retained the case for review.The Supreme Court affirmed the district court's decision. It held that the plaintiffs' grievances did not fall within the scope of Oklahoma's public nuisance statute. The court also found that the plaintiffs' allegations did not support a claim for unjust enrichment under the equitable doctrine. The court noted that the plaintiffs' grievances were legitimate but stated that the law did not permit the court to extend the scope of the public nuisance doctrine or the doctrine of unjust enrichment to provide the plaintiffs with the justice they sought. View "Randle v. City of Tulsa" on Justia Law

The case revolves around the issue of whether a guardian can initiate a divorce proceeding on behalf of an incapacitated ward. Peter Galbraith, II, the ward, and Belinda Galbraith were married in 2015. Between 2018 and 2019, Mr. Galbraith became ill with Frontotemporal Dementia BV. Mrs. Galbraith obtained a power of attorney and later deeded the marital residence to her separate trust. In 2022, she asked Mr. Galbraith's brother and mother to take care of him, and he was moved out of the marital home. In 2023, Mr. Galbraith's brother and mother petitioned the court for a general guardianship over him and filed a Petition for the Dissolution of Marriage without first obtaining authorization from the guardianship court. Mrs. Galbraith filed a motion for summary judgment alleging the guardians lacked authority to initiate a divorce proceeding on behalf of the ward. The trial court agreed and granted the motion.The trial court initially held that the guardian did not have the authority to file a divorce petition on behalf of the ward. After obtaining authorization from the guardianship court, the guardian refiled the petition. However, the trial court again dismissed the petition, stating that Oklahoma law does not allow a guardian to initiate a divorce on behalf of a ward. The guardian appealed this decision to the Supreme Court of the State of Oklahoma.The Supreme Court of the State of Oklahoma reversed the trial court's decision. The court held that the Oklahoma Guardianship and Conservatorship Act does not explicitly disallow the guardianship court from authorizing a guardian to file a divorce petition on behalf of a ward. The court found that the guardian was acting to protect the ward's rights and manage his financial resources, which aligns with the purpose of the Act. The court also held that the addressed provisions of title 43 of the Oklahoma Statutes do not act as a bar to the initiation of such an action by the guardian. The court concluded that the guardianship court may authorize a guardian to initiate a divorce action on behalf of a ward. The case was remanded for further proceedings. View "GALBRAITH v. GALBRAITH" on Justia Law

The case revolves around an incident where an employee, Leonard Bernstein, shot his co-worker, Christopher Bayouth, at their workplace, Morgan Stanley's Oklahoma City branch. Bernstein, who was suffering from mental deficiencies, believed he was acting in self-defense due to his delusional state. After the shooting, Bayouth filed a lawsuit against Bernstein for willful and intentional acts, assault, battery, and intentional infliction of emotional distress. Bernstein passed away, and his estate was substituted as the defendant. The estate argued that Bayouth's exclusive remedy was through the Administrative Workers' Compensation Act (AWCA), as he had received workers' compensation benefits.The District Court of Oklahoma County granted summary judgment in favor of Bernstein's estate, ruling that the exclusive remedy provision of the AWCA protected Bernstein regardless of whether he was acting within his course and scope of employment when the shooting occurred. The court reasoned that the focus was on whether the injured employee was acting within the course and scope of his employment at the time of the incident, not the employee who caused the injury.The Supreme Court of the State of Oklahoma disagreed with the lower court's interpretation. The court held that for the exclusive remedy provision under the AWCA to apply, the employee who injures another employee must be acting within the course and scope of their employment when the incident occurs. The court found that the parties disputed whether Bernstein was acting within the course and scope of his employment when he shot Bayouth. Therefore, the court reversed the lower court's decision and remanded the case for further proceedings. View "Bayouth v. Dewberry" 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 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

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