STRICKLAND v. STEPHENS PRODUCTION COMPANY, 411 P.3d 369

Decedent David Chambers, an RDT Trucking employee, died from severe burns while working at a well site operated by Stephens Production Company (SPC).
Plaintiff Glory Strickland (Special Administrator) sued SPC for wrongful death alleging negligence in operation, maintenance, inspection, and warning of dangerous conditions.
SPC moved to dismiss under 85A O.S. Supp. 2013 § 5(A) (OAWCA), which makes owners/operators of oil and gas wells "deemed to be an intermediate or principal employer" for immunity from civil tort suits.
The district court denied dismissal, holding the last sentence of § 5(A) an unconstitutional special law; certified the interlocutory order for review.
The Oklahoma Supreme Court granted certiorari to decide whether the statute's automatic deeming of oil/gas owners/operators as principal employers violates Art. 5, § 59 of the Oklahoma Constitution.
The Court severed the last sentence of § 5(A) (invalidating the industry-specific deeming provision) but left the remainder of § 5(A) intact; SPC may still attempt to prove principal/employer status under traditional tests on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the last sentence of 85A § 5(A) (automatically deeming oil/gas owners/operators principal/intermediate employers) is a prohibited special law under Okla. Const. Art. 5, § 59	Strickland: The provision singles out oil/gas industry without a distinctive characteristic or reasonable basis and thus is an unconstitutional special law	SPC: Oil/gas industry is unique (complex processes, multiple subcontractors) and needs certainty of immunity; statute reasonably related to legislative objective	The last sentence is an impermissible special law (violates Art. 5, § 59) and is unconstitutional; struck and severed
Whether the unconstitutional clause is severable from § 5(A)	Strickland: The core exclusive-remedy language is independent and would survive	SPC: (implicitly) the provision is integral to the statute's operation	Court: Clause is severable; remaining exclusive-remedy language remains effective; parties may still litigate principal-employer status under existing common-law/statutory tests

Grant v. Goodyear Tire & Rubber Co., 5 P.3d 594 (Okla. 2000) (invalidating legislative singling out of one industry under workers' compensation as unconstitutional special law)
Smalygo v. Green, 184 P.3d 554 (Okla. 2008) (describing reach of vertical/secondary employer liability in workers' compensation context)
Bradley v. Clark, 804 P.2d 425 (Okla. 1990) (applying necessary-and-integral test to reject principal-employer status for hirer)
TXO Production Corp. v. Oklahoma Corporation Commission, 829 P.2d 964 (Okla. 1992) (statutory construction principle: when legislature reenacts similar language, court applies prior judicial constructions)
Lee v. Bueno, 381 P.3d 736 (Okla. 2016) (standard: statutory constitutional challenges reviewed de novo)
Naifeh v. Oklahoma Tax Comm'n, 400 P.3d 759 (Okla. 2017) (severability analysis framework)