LOCKETT v. EVANS
330 P.3d 488
| Okla. | 2014Background
- Condemned inmates filed a declaratory-judgment action under 12 O.S. § 1651 et seq. challenging confidentiality language in 22 O.S. § 1015(B) that shields identities of execution participants and suppliers.
- The district court declared § 1015(B)’s confidentiality provision unconstitutional and plaintiffs sought relief; DOC and Attorney General appealed.
- This Court exercised expedited appellate review, stayed the executions pending review, and treated the stay as “further relief” under the Declaratory Judgment Act.
- The DOC had already disclosed its execution protocol and the identity of the drug(s) and dosages to be used; the secrecy clause did not, by its terms, conceal the drug identity or dosage.
- This Court limited its review to the declaratory-judgment issue and did not address validity of the underlying criminal judgments or sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1015(B)’s confidentiality of execution participants/suppliers violates inmates’ right of access to courts | Lockett: secrecy of suppliers/participants prevents effective litigation of Eighth Amendment claims (need identities to investigate and litigate) | DOC: inmates already know drugs and dosages; secrecy protects individuals but does not impede access to courts | Held: No access-to-courts violation; inmates failed to show actual prejudice required by Lewis v. Casey |
| Whether DOC execution protocol is a "rule" requiring APA rulemaking procedures | Lockett: protocol should be treated as a rule subject to APA procedures (public notice, hearings) | DOC: protocol is internal management (exempt under 75 O.S. § 250.4(10)) and not a rule under the APA definition | Held: Protocol is internal management, exempt from Article I rulemaking requirements of the APA |
| Scope of relief available after declaratory judgment under 12 O.S. § 1655 | Plaintiffs: sought injunction/relief to force disclosure beyond declaratory judgment | DOC: further relief must be appropriate and consistent with jurisdictional limits | Held: Court may grant "further relief" (it did via stay earlier); but declaratory judgment that secrecy provision was unconstitutional is reversed in part |
| Whether district court exceeded jurisdiction by declaring § 1015(B) unconstitutional | Plaintiffs: district court properly exercised declaratory-judgment jurisdiction under § 1653(C) | DOC: appellate boundaries and criminal appellate jurisdiction issues implicated; some justices argued transfer to Court of Criminal Appeals | Held: Court exercised appellate jurisdiction; decision affirms denial of prisoners’ relief and reverses district court’s declaration that § 1015(B) was unconstitutional; stay dissolved |
Key Cases Cited
- Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires showing of actual injury)
- Trask v. Johnson, 452 P.2d 575 (Okla. 1969) (purpose of Oklahoma Administrative Procedures Act)
- Middleton v. Missouri Dept. of Corrections, 278 S.W.3d 193 (Mo. 2009) (prison internal procedures need not follow public rulemaking)
- Abdur'Rahman v. Bredesen, 181 S.W.3d 292 (Tenn. 2005) (similar exemption for internal corrections procedures)
- Conner v. North Carolina Council of State, 716 S.E.2d 836 (N.C. 2011) (execution protocol treated as internal management)
- Anderson v. Trimble, 519 P.2d 1352 (Okla. 1974) (limits on declaratory-judgment relief regarding penal statutes)
- Carder v. Court of Criminal Appeals, 595 P.2d 416 (Okla. 1978) (respecting jurisdictional boundaries between appellate courts)