AGRAWAL v. OKLAHOMA DEPT. OF LABOR
2015 OK 67
| Okla. | 2015Background
- Christopher Holland filed a wage claim with the Oklahoma Department of Labor (ODOL) alleging unpaid wages (initially $36,750, later $34,350) for work performed for businesses tied to Kris and Vimala Agrawal.
- Holland's claim named multiple corporate entities and the Agrawals; notices by certified mail were returned refused for several entities; counsel Vincent entered appearance and later withdrew.
- ODOL issued an Administrative Order awarding wages and liquidated damages (total $68,700); appellants requested an administrative hearing and received substitutional service before the prehearing conference.
- At the administrative hearing Holland testified he was hired and supervised by Kris Agrawal, often working interchangeably for several entities and keeping non‑contemporaneous records; ODOL admitted Holland’s exhibit listing dates/hours but refused appellants’ late-submitted evidence since they missed the prehearing conference.
- The ALJ found Agrawal personally liable (treating entities as controlled by the Agrawals/alter egos), affirmed the wage award, and the district court affirmed on APA review; the Supreme Court of Oklahoma affirmed.
Issues
| Issue | Plaintiff's Argument (Holland) | Defendant's Argument (Agrawal) | Held |
|---|---|---|---|
| Whether ODOL could allow joinder of multiple employers in one wage claim | Joinder permissible; statutes don’t prohibit joinder of multiple employers and permissive-joinder rules support it | Joinder improper under 40 O.S. §165.7(B); claim initially against GEO only and amendment/nameing caused ambiguity and unfair aggregation | Joinder/joinder amendment was permissible; ALJ’s finding of personal liability against Agrawal supported by evidence and not barred by §165.7(B) |
| Whether ALJ erred by prohibiting appellants from presenting evidence at the administrative hearing | N/A (Holland opposed late evidence) | Refusal to allow evidence denied appellants fair hearing; lack of notice and inability to present witnesses/exhibits prejudiced them | ALJ did not abuse discretion; appellants had notice (including via counsel and substitutional service) and missed prehearing obligations, so exclusion of late evidence was proper |
| Whether service/notice was constitutionally sufficient | Service via counsel and substitutional posting sufficed; appellants had constructive/actual notice | Service was inadequate (certified mail returned refused; they did not receive prehearing materials) | Service was sufficient (entry of appearance by counsel and substitutional service satisfied due process); defendants had opportunity to be heard earlier |
Key Cases Cited
- Oklahoma Dept. of Public Safety v. McCrady, 176 P.3d 1194 (Okla. 2007) (standard of APA review; courts defer to agency on factual findings if supported by substantial evidence)
- Stipe v. State ex rel. Bd. of Trustees of the Oklahoma Pub. Employees Retirement System, 188 P.3d 120 (Okla. 2008) (agency statutory interpretation may stand absent legislative disapproval)
- Scott v. Oklahoma Secondary School Activities Ass'n, 313 P.3d 891 (Okla. 2013) (reaffirms appellate standard to affirm agency order when supported by substantial evidence)
- Daniels v. Daniels, 634 P.2d 709 (Okla. 1981) (service on attorney of record creates presumption notice reaches client and satisfies due process)