CHRISTIAN v. LEE
2016 OK 115
| Okla. | 2016Background
- Plaintiff Sammy Lee Christian sought declaratory relief declaring 12 O.S. § 3009.1 unconstitutional after the trial court ruled the statute invalid on multiple constitutional grounds.
- Trial court held § 3009.1: (1) was a special law in violation of Okla. Const. art. 5, § 46; (2) arbitrarily burdened the right to jury trial (art. 2, § 19); (3) violated access-to-courts (art. 2, § 6); and (4) violated due process (art. 2, § 7) and the federal Constitution; it also found inconsistency with the collateral source rule.
- The trial court certified the order for interlocutory review and the matter reached the Oklahoma Supreme Court by appeal.
- The Oklahoma Supreme Court reviewed the record and briefs and determined that its recent decision in Lee v. Bueno, 2016 OK 97, 381 P.3d 736, was dispositive.
- Applying Lee v. Bueno, the Supreme Court summarily reversed the trial court’s declaratory judgment and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 3009.1 is a prohibited special law | Christian: statute is a special law in violation of Okla. Const. art. 5, § 46 | Lee: statute is not a special law; applies generally as written | Reversed trial court — Lee v. Bueno controls; statute not struck on this basis |
| Whether § 3009.1 unlawfully burdens the right to jury trial | Christian: imposes arbitrary burdens on jury right (art. 2, § 19) | Lee: procedural limits do not impermissibly infringe jury rights | Reversed trial court — claim addressed and resolved by Lee v. Bueno |
| Whether § 3009.1 denies access to courts | Christian: statute restricts plaintiffs’ access to remedies (art. 2, § 6) | Lee: statute does not improperly bar access; provides admissibility rule only | Reversed trial court — dispositive authority in Lee v. Bueno |
| Whether § 3009.1 violates due process or conflicts with collateral source rule | Christian: statute violates due process and conflicts with collateral source rule | Lee: statute is constitutionally permissible and consistent with evidentiary rules | Reversed trial court — Lee v. Bueno resolved these constitutional and evidentiary challenges |
Key Cases Cited
- Lee v. Bueno, 381 P.3d 736 (Okla. 2016) (Oklahoma Supreme Court decision deemed dispositive; led to reversal of trial court’s invalidation of 12 O.S. § 3009.1)