History
  • No items yet
midpage
STEIDLEY v. SINGER
2017 OK 8
| Okla. | 2017
Read the full case

Background

  • In Oct 2013 three prosecutors (Steidley, Iski, Lair) sued several private citizens, alleging the citizens filed a grand-jury-petition containing false and reckless accusations.
  • The grand-jury petition was filed/approved in Aug 2013; the plaintiffs amended their petition in Nov 2013.
  • Defendants answered and, after the case remained pending, the Oklahoma Citizens Participation Act (OCPA) was substantially rewritten and became effective Nov 1, 2014.
  • The OCPA permits an early motion to dismiss suits that are based on petitioning, speech, or association, suspends discovery, and shifts costs/fees to prevailing movants.
  • Defendants moved to dismiss under the OCPA; the trial court denied dismissal as inapplicable retroactively; the Court of Civil Appeals affirmed. Supreme Court granted certiorari to decide retroactivity.
  • The Supreme Court held the OCPA does not apply retroactively and affirmed the lower courts, remanding for further proceedings.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the OCPA applies retroactively to suits filed before its effective date OCPA should not apply retroactively; applying it would impair matured rights and change substantive remedies OCPA applies to pending cases and defendants are entitled to dismissal under its provisions The OCPA does not apply retroactively; it must be applied prospectively to actions filed after Nov. 1, 2014

Key Cases Cited

  • King Mfg. v. Meadows, 127 P.3d 584 (Okla. 2005) (discusses limits on retroactive statutory changes to vested rights)
  • Cole v. Silverado Food, Inc., 78 P.3d 542 (Okla. 2003) (addresses effect of legislative change on accrued rights and proceedings)
  • Williams Companies, Inc. v. Dunkelgod, 295 P.3d 1107 (Okla. 2012) (analyzes distinction between procedural and substantive statutory changes for retroactivity)
  • Forest Oil Corp. v. Corp. Comm'n of Oklahoma, 807 P.2d 774 (Okla. 1990) (holds repeal or amendment cannot affect accrued rights or pending proceedings in certain circumstances)
Read the full case

Case Details

Case Name: STEIDLEY v. SINGER
Court Name: Supreme Court of Oklahoma
Date Published: Jan 24, 2017
Citation: 2017 OK 8
Court Abbreviation: Okla.