McGee v. Amoco Production Co.

Summary

The Oklahoma Supreme Court vacated an order denying Amoco Production Company's motion to disqualify opposing counsel. The court held that the trial court was required to provide findings establishing the factual and legal basis for its rulings on alleged conflicts of interest and standing, even though the alleged conflict involved economic interests rather than confidential information. The matter was remanded for further proceedings and a sufficiently supported final order.

Holdings

1. A trial court denying a motion to disqualify counsel must submit written findings or create a record setting forth the factual and legal support for its ruling, even when the alleged conflict is based on economic interests rather than possession of confidential information.
2. When denying a motion to disqualify counsel on standing grounds, the trial court must identify the facts and legal support for its determination that the movant does or does not have standing to challenge the alleged conflict.

Questions Presented

1. Whether an order denying a motion to disqualify counsel must contain specific factual and legal findings or be supported by a record sufficient for meaningful appellate review.
2. Whether the trial court was required to make specific findings concerning Amoco's standing to challenge the alleged conflict of interest.

Disposition

vacated