LADRA v. NEW DOMINION, LLC
2015 OK 53
| Okla. | 2015Background
- Plaintiff Sandra Ladra was injured in her Prague, Oklahoma home when rock from her chimney fell during a November 5, 2011 earthquake; she sued owners/operators of nearby wastewater injection wells claiming the wells caused the seismic event and her injuries.
- Ladra filed a private tort action in Lincoln County District Court seeking compensatory and punitive damages (claims exceeding $75,000).
- Defendants (New Dominion, Spess Oil, and others) moved to dismiss, arguing the Oklahoma Corporation Commission (OCC) has exclusive jurisdiction over disputes involving injection wells.
- The district court granted the motions and dismissed the case; Ladra appealed to the Oklahoma Supreme Court.
- The Supreme Court considered whether the OCC's statutory jurisdiction over oil and gas operations precluded district-court jurisdiction over private tort claims alleging injury from regulated activity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the OCC has exclusive jurisdiction over Ladra's private tort claims arising from injection-well operations | Ladra: Her claim is a private tort seeking money damages for personal injury; such claims belong in district court, not before the OCC | Defendants: OCC has exclusive jurisdiction over matters involving exploration, injection, disposal of brines/wells, so the OCC must adjudicate any dispute arising from those operations | Held: District court has jurisdiction over private tort actions; OCC's exclusive jurisdiction is limited to public-rights/regulatory matters and does not bar private damage suits |
| Whether Ladra's suit impermissibly collaterally attacks OCC orders or requires review/modification of OCC orders | Ladra: Suit seeks damages only, not reversal or modification of any OCC order | Defendants: Allowing suit would improperly infringe on OCC's authority or amount to collateral attack | Held: District court may adjudicate private claims; plaintiffs cannot use district court to reverse/modify OCC orders, but private suits seeking damages are not barred so long as they do not collaterally attack OCC orders |
Key Cases Cited
- Marathon Oil Co. v. Corporation Comm'n of State of Okla., 910 P.2d 966 (Okla. 1994) (describing OCC's exclusive jurisdiction over certain oil-and-gas matters)
- Kingwood Oil Co. v. Hall-Jones Oil Corp., 396 P.2d 510 (Okla. 1964) (recognizing district courts retain jurisdiction over private tort suits even when regulated operations are implicated)
- Rogers v. Quiktrip Corp., 230 P.3d 853 (Okla. 2010) (OCC lacks authority to resolve purely private disputes where public interest is not involved)
- Grayhorse Energy, LLC v. Crawley Petroleum Corp., 245 P.3d 1249 (Okla. Civ. App. 2010) (private tort actions against operators are within district-court authority despite OCC regulation)
- NBI Services, Inc. v. Ward, 132 P.3d 619 (Okla. Civ. App. 2006) (negligence and strict-liability determinations involving regulated activity belong in district court)
- Pelican Production Corp. v. Wishbone Oil & Gas, Inc., 746 P.2d 209 (Okla. Civ. App. 1987) (district court may only inquire into whether OCC had jurisdiction; cannot reverse OCC orders by collateral attack)