KNOX v. OKLAHOMA COURT OF CRIMINAL APPEALS, 390 P.3d 237

Petitioner Antone Lamadingo Knox filed a motion titled as writs of mandamus and prohibition seeking vacation of his criminal judgment and sentence and requesting oral argument and an evidentiary hearing.
The Oklahoma Supreme Court treated the filings on substance, not title, and construed them as a petition for a writ of habeas corpus to inquire into the legality of Knox’s detention.
Knox named the Oklahoma Court of Criminal Appeals and its judges as respondents, alleging those rulings failed to provide relief from his criminal conviction.
The Oklahoma Supreme Court does not have appellate jurisdiction over criminal convictions; the Court of Criminal Appeals has exclusive appellate jurisdiction in criminal matters.
The Supreme Court assumed original jurisdiction solely to determine whether it had jurisdiction to proceed, then declined to assume jurisdiction on the merits and denied the habeas petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper characterization of pleadings	Knox contends his motion seeks vacation of conviction and procedural relief (argument framed as mandamus/prohibition).	Court treats substance over title and recharacterizes as habeas corpus because it challenges detention legality.	The Court construed the filings as a habeas corpus petition.
Whether Oklahoma Supreme Court has jurisdiction to review criminal conviction	Knox argues this Court should hear his challenge and not transfer the matter.	State (implicitly) notes that criminal appellate jurisdiction resides exclusively with the Court of Criminal Appeals.	The Supreme Court lacks original jurisdiction to adjudicate the criminal-conviction challenge and declines to hear the merits.
Whether petition raises institutional-defect claim against Court of Criminal Appeals	Knox asserts the Court of Criminal Appeals’ rulings denied him relief.	Respondents argue these allegations do not amount to a legally cognizable institutional deficiency.	Court finds no cognizable institutional-deficiency issue and rejects that basis for jurisdiction.
Whether habeas relief should be granted on the merits	Knox seeks vacation of judgment/sentence and evidentiary hearing.	Respondents contend the Supreme Court should not assume merits jurisdiction over criminal claims.	The Court declines to assume merits jurisdiction and denies the petition for writ of habeas corpus.

Brooks v. Baltz, 12 P.3d 467 (Okla. 2000) (habeas corpus is a summary inquiry into legality of detention)
Application of Caldwell, 525 P.2d 641 (Okla. 1974) (purpose and scope of habeas corpus)
State ex rel. Dept. of Transportation v. Cole, 236 P.3d 49 (Okla. 2009) (effect of pleading determined by substance, not title)
State ex rel. Wright v. Oklahoma Corp. Comm., 170 P.3d 1024 (Okla. 2007) (substance-over-form principle for procedural filings)
Dutton v. City of Midwest City, 353 P.3d 532 (Okla. 2015) (Supreme Court lacks appellate jurisdiction over criminal causes; Court of Criminal Appeals has exclusive appellate jurisdiction)
Clark v. Farris, 358 P.3d 932 (Okla. 2015) (assumption of original jurisdiction solely to determine whether court has jurisdiction to proceed)