HALL v. THE GEO GROUP, INC
2014 OK 22
| Okla. | 2014Background
- Walter Hall, an inmate transferred to GEO (a private prison) in April 2010, suffered a subdural hematoma from an earlier fall and later was confined to a wheelchair.
- On September 7, 2010, GEO transported Hall to a medical appointment; his wheelchair was unsecured, toppled when the van moved abruptly, and Hall alleges he was re-injured.
- Hall filed suit for negligence against GEO on June 18, 2012 — about 2 years and 9 months after the incident. GEO moved for summary judgment asserting the claim was time-barred.
- Hall argued the one-year inmate limitations period was tolled by legal disability/incapacity and also raised constitutional equal protection challenges to the limitations rule.
- The Supreme Court held 57 O.S. §566.4 applies: prisoners (or former prisoners) bringing tort claims against private correctional facilities must comply with the Governmental Tort Claims Act (GTCA) notice provisions; compliance is jurisdictional.
- Because Hall did not file the GTCA notice and the GTCA tolls incapacity only up to 90 days, his suit was untimely and must be dismissed; the trial court’s grant of summary judgment was affirmed (on this basis).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GTCA notice provisions apply to tort suits by prisoners against private prisons | Hall did not address §566.4 but implicitly argued state inmate limitations governed; he also contended incapacity tolled the period | GEO argued §566.4 requires GTCA notice and that Hall failed to comply, so suit is jurisdictionally barred | §566.4 applies; GTCA notice is mandatory and jurisdictional for suits against private correctional facilities |
| Whether Hall's claim was timely under applicable limitations/tolling | Hall argued legal disability/incapacity tolled the limitations and tried to invoke general tolling statutes | GEO argued the GTCA timetable controls and Hall failed to give notice within GTCA deadlines | GTCA controls; incapacity tolling under GTCA limited to 90 days, so Hall’s suit was untimely |
| Whether the one-year inmate limitations statute (§95(11)) or GTCA governs | Hall relied on §95(11) and general tolling rules | GEO relied on GTCA notice deadlines (51 O.S. §§156–157) as extended to private prisons by 57 O.S. §566.4 | GTCA (as applied via §566.4) governs; §95(11) need not be reached |
| Constitutional challenge to GTCA notice/limitations (equal protection / special law) | Hall argued inmate-only limitations or notice rules were unconstitutional special laws/denied equal protection | GEO argued extending GTCA notice to private prisons ensures uniform treatment and GTCA has been upheld previously | Court rejected constitutional challenge, finding Legislature’s extension promotes equal treatment and prior precedents uphold GTCA provisions |
Key Cases Cited
- Harmon v. Cradduck, 286 P.3d 643 (Okla. 2012) (notice under GTCA is jurisdictional prerequisite)
- Cruse v. Bd. of Cnty. Comm’rs of Atoka Cnty., 910 P.2d 998 (Okla. 1996) (general savings statutes do not apply where GTCA provides specific provisions)
- Duncan v. City of Nichols Hills, 913 P.2d 1303 (Okla. 1996) (compliance with GTCA notice is condition precedent to suit)
- Rout v. Crescent Pub. Works Auth., 878 P.2d 1045 (Okla. 1994) (limitations within GTCA control over general statutory law)
- Dixon v. Bhuiyan, 10 P.3d 888 (Okla. 2000) (appellate court may affirm trial court on correct result even if for different reasoning)