HALL v. THE GEO GROUP, INC, 2014 OK 22

Hall, an inmate, suffered a head injury and wheelchair confinement after a hospital fall and pituitary/hematoma treatment.
He was transferred to GEO, a private correctional facility, on April 28, 2010.
On Sept 7, 2010, GEO transported Hall in a van; the wheelchair toppled when the driver moved the van, allegedly causing injuries.
Hall filed suit June 18, 2012, arguing GEO was negligent; GEO moved for summary judgment arguing timeliness.
The trial court granted summary judgment; the Oklahoma Supreme Court held GTCA notice requirements apply to torts against private correctional facilities, and Hall failed to comply, making the action untimely.
Court affirmed dismissal for lack of timely GTCA notice and lack of jurisdiction to proceed against GEO against Hall’s claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is GTCA notice a jurisdictional prerequisite for prisoner claims against private correctional facilities?	Hall contends limitations apply.	GEO argues GTCA notice is mandatory and jurisdictional.	Yes; GTCA notice is jurisdictional and required before filing.

Harmon v. Cradduck, 2012 OK 80, 286 P.3d 643 (OK Supreme Court 2012) (notice is a jurisdictional prerequisite to GTCA actions)
Cruse v. Board of County Commissioners of Atoka County, 1995 OK 143, 910 P.2d 998 (OK Supreme Court 1995) (rules on exhaustion of remedies and GTCA applicability)
Duncan v. City of Nichols Hills, 1996 OK 16, 913 P.2d 1303 (OK Supreme Court 1996) (GTCA compliance as a condition precedent to suit)
Jarvis v. City of Stillwater, 1987 OK 5, 732 P.2d 470 (OK Supreme Court 1987) (upholds strict notice requirements under GTCA)
Anderson v. Eichner, 1994 OK 136, 890 P.2d 1329 (OK Supreme Court 1994) (upholds GTCA notice/exhaustion framework)
Dixon v. Bhuiyan, 2000 OK 56, 10 P.3d 888 (OK Supreme Court 2000) (general savings vs. GTCA-specific provisions)