IN THE MATTER OF K.S., 393 P.3d 715

Biological mother (Williams) had parental rights to K.S. terminated by district court on Nov. 19, 2013; that judgment was affirmed on appeal and mandate issued Feb. 13, 2015.
Child was adopted after termination; adoptive parents became legal "Parents" and adoption records are confidential under 10 O.S. § 7505-1.1.
On April 7, 2015 Williams filed a petition for guardianship of K.S.; the district court denied the petition without prejudice for failure to provide required notice to the minor’s parents and struck a scheduled hearing.
Williams filed multiple motions for reconsideration and a second “Motion of Motion” (May 20, 2015) asserting she had provided notice by USPS and that the court improperly struck the hearing.
The district court denied the motions, citing lack of required notice under the Oklahoma Guardianship and Conservatorship Act and authority to decide motions without a hearing under Rule 4(h).
Williams timely appealed only as to the June 4, 2015 denial of the second motion for reconsideration; the Supreme Court affirmed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of guardianship petition for failure to notify Parents deprived court of jurisdiction	Williams: she provided notice via USPS; court should proceed	State: Parents must be notified; adoption confidentiality prevents Williams from identifying Parents so notice was not given	Court: Affirmed — lack of notice meant court lacked jurisdiction to appoint guardian
Whether court abused discretion by deciding motions without a hearing / striking the scheduled hearing	Williams: striking the hearing was untimely and prejudiced her travel reliance	State: Rule 4(h) permits deciding motions without a hearing; no required advance timing; plus no jurisdiction for guardianship hearing	Court: Affirmed — Rule 4(h) allows deciding without hearing and striking hearing was not abuse of discretion
Whether the motions were procedurally sufficient to extend appeal time	Williams: later motions tolled appeal time	State: Only timely post-trial motions (within 10 days) extend appeal time; later motions do not	Court: Only the second motion denial was timely appealed; other filings did not extend appeal period
How to treat a "motion to reconsider"	Williams: entitled to reconsideration/hearing	State: Substance controls; such motions may be treated as new trial or motion to vacate under §§ 651 or 1031; standard is abuse of discretion	Court: Substance governs; denial reviewed for abuse of discretion and none found

Smith v. City of Stillwater, 328 P.3d 1192 (Okla. 2014) (treats substantive content over motion title; standard for reviewing motions to reconsider)
Kerr v. Clary, 37 P.3d 841 (Okla. 2001) (court looks to motion substance to determine treatment)
Bank of Oklahoma, N.A. v. Red Arrow Marina Sales & Service, Inc., 224 P.3d 685 (Okla. 2009) (abuse of discretion standard and review principles)
Bierman v. Aramark Refreshment Servs., Inc., 198 P.3d 877 (Okla. 2008) (finality of judgment upon issuance of mandate)
Read v. Read, 57 P.3d 561 (Okla. 2001) (claim preclusion bars relitigation of matters decided in prior proceedings)
Brigman v. Cheney, 112 P. 993 (Okla. 1910) (appointment of guardian reviewed for abuse of discretion)