2018 OK 21
Okla.2018Background
- Plaintiff Frank Benedetti, a Schlumberger employee, fell over 30 feet on an Oklahoma oil-rig site and sued Cimarex (site owner/operator) for negligence.
- Cimarex moved to dismiss asserting statutory immunity under 85 O.S. § 302(H) (Workers' Compensation Code) treating owners/operators as intermediate/principal employers.
- District court granted the dismissal under § 302(H); the Court of Civil Appeals affirmed; Benedetti sought certiorari to the Oklahoma Supreme Court.
- Benedetti argued § 302(H) is an unconstitutional special law under Okla. Const. art. 5, § 59; Cimarex argued § 302(H) properly channels claims to workers' comp and extends immunity.
- The Supreme Court, relying on its reasoning in Strickland v. Stephens Production Co., held § 302(H) is an unconstitutional special law and severed subsection (H) from § 302.
- The case was remanded for further proceedings and discovery on whether Cimarex may nonetheless qualify as Benedetti’s principal employer under other statutory provisions (85 O.S. § 314 / necessary-and-integral test).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 85 O.S. § 302(H) is a constitutional statute or an unconstitutional special law | § 302(H) discriminates unreasonably between classes and violates Art. 5, § 59 | § 302(H) properly extends Workers' Comp immunity to oil/gas operators, promotes public good and claim-channeling | § 302(H) is an unconstitutional special law and is severed from § 302 |
| Whether dismissal was proper without further fact development on principal-employer status | Benedetti urged further discovery; master service agreement alone insufficient to show principal-employer status | Cimarex treated the agreement as dispositive to establish principal-employer immunity | Case remanded for discovery and factual development under § 314 (necessary-and-integral test); dismissal reversed |
| Whether the district court or COCA properly converted the motion to dismiss into summary judgment | Benedetti contended conversion was improper because parties did not treat it as summary judgment and discovery was needed | Cimarex relied on the attached agreement to support its motion | Court noted conversion was improper where motion challenged jurisdiction and parties lacked opportunity for discovery; remand ordered |
| Whether other Workers' Compensation provisions preclude civil suit absent § 302(H) | Benedetti argued other statutory tests require factual inquiry and cannot be decided on present record | Cimarex argued other statutes (e.g., § 314) support intermediate/principal employer status | Court allowed Cimarex to reassert exclusive-remedy defenses after discovery; no bar on reargument |
Key Cases Cited
- Hammock v. United States, 78 P.3d 93 (Okla. 2003) (explains the necessary-and-integral test for statutory employer status)
- Bradley v. Clark, 804 P.2d 425 (Okla. 1990) (discusses factors for determining statutory employer/principal employer)
- Lafalier v. Lead-Impacted Communities Relocation Assistance Trust, 237 P.3d 181 (Okla. 2010) (burden on challenger to show statute unconstitutional)
- Samson Resources Co. v. Newfield Exploration Mid-Continent, Inc., 281 P.3d 1278 (Okla. 2012) (procedural rules on conversion of motions to dismiss into summary judgment)
- Lee v. Bueno, 381 P.3d 736 (Okla. 2016) (standards for de novo review of statutory constitutionality)