STATE ex rel. PRUITT v. STEIDLEY
2015 OK CR 6
| Okla. Crim. App. | 2015Background
- The Oklahoma Attorney General (AG) filed two extraordinary writ applications challenging District Judge J. Dwayne Steidley's orders that barred the AG from taking and assuming control of prosecutions in two Rogers County criminal cases (CF-2013-535 and CF-2014-5) under 74 O.S. § 18b(A)(3).
- The AG entered appearances in the district court citing § 18b(A)(3); defense counsel and Judge Steidley objected, arguing the AG may act only when requested by the Governor or Legislature.
- This Court stayed both district-court proceedings and solicited responses from Judge Steidley and the Rogers County District Attorney; responses and procedural filings followed.
- The District Attorney acknowledged concurrent authority but contended the trial court should limit or define the AG’s role and resisted displacement of the elected DA.
- The Court analyzed statutory text and legislative amendments (notably the 1995 amendment to § 18b(A)(3)) and concluded the AG may initiate or appear in actions affecting state interests and, when so appearing, may take and assume control of the prosecution; any DA role becomes subservient.
- The Court granted the writs of prohibition, held Judge Steidley’s orders were unauthorized, lifted the prior stays, and remanded the cases for proceedings consistent with its order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether AG may independently appear and assume control of prosecution under 74 O.S. § 18b(A)(3) | AG: statute authorizes AG to initiate or appear in any action affecting state interests and, when so appearing, to take and assume control if advisable | Judge/defendants: § 18b(A)(3) permits appearance only at request of Governor or Legislature; AG cannot unilaterally supplant elected DA | Held: The amended § 18b(A)(3) authorizes AG to initiate/appear and, when doing so, to take and assume control; DA’s role is subordinate when AG enters under § 18b(A)(3). |
| Whether Judge Steidley’s orders prohibiting AG entry were legally authorized | AG: orders unauthorized; writ of prohibition appropriate | Judge: relied on his statutory interpretation limiting AG authority to requests by Governor/Legislature | Held: Judge’s orders were unauthorized; writs granted. |
| Whether statutes for AG (§ 18b) and DAs (§ 215.4) conflict and which controls | AG: § 18b(A)(3) as amended permits AG action even where DA also has authority | DA: authorities are concurrent; AG should not be superior to DA absent request; court should tailor roles | Held: Statutes are not in conflict; § 18b(A)(3) (as latter provision) controls to the extent AG appears under it; DA’s authority becomes subservient. |
| Whether writ of prohibition standards are met | AG: Judge’s action is judicial power unauthorized by law and causes injury without adequate remedy | Judge/defense: argued statutory limits to AG authority justify order | Held: All three prohibition elements met; extraordinary relief granted and matters remanded. |
Key Cases Cited
- State v. Stice, 288 P.3d 247 (2012) (summarizes statutory interpretation principles applied to reconcile statutes)
- Lozoya v. State, 932 P.2d 22 (1996) (rules that statutes be construed to effect legislative intent and give intelligent effect to each part)
- Wallace v. State, 935 P.2d 366 (1997) (affirming plain-meaning approach to statutory construction)
- Vilandre v. State, 113 P.3d 893 (2005) (cautions against statutory constructions that render provisions superfluous)