Greenwood Centre, Ltd.; John Hope Franklin Center for Reconciliation, Inc.; Shannon Martin; and Bim Stephen Bruner v. Rebecca Brett Nightingale

Greenwood Centre, Ltd. v. Nightingale, 2020 OK 59 · Supreme Court of Oklahoma · June 23, 2020 · No. 118860

Summary

The Oklahoma Supreme Court denied petitioners' application to assume original jurisdiction and their requested writ of mandamus concerning social-distancing requirements for a presidential campaign rally at Tulsa's BOK Center. The court concluded that petitioners lacked a clear legal right to relief because the applicable state and local guidance was permissive and discretionary rather than mandatory. Separate concurring writings addressed the discretionary nature of the applicable guidance and the court's role in applying, rather than creating, legal requirements.

Court
Supreme Court of Oklahoma
Writing for the Court
Chief Justice Gurich; Vice Chief Justice Darby; Justice Kauger; Justice Winchester; Justice Edmondson; Justice Colbert; Justice Combs; Justice Kane; Justice Rowe
Jurisdiction
Oklahoma
Decision date
June 23, 2020
Docket number
118860
Procedural posture
Petitioners applied for the Oklahoma Supreme Court to assume original jurisdiction and issue a writ of mandamus and injunctive relief concerning social-distancing requirements for a proposed presidential campaign rally at the BOK Center in Tulsa.
Standard of review
To obtain mandamus relief, petitioners must establish, among other elements, a clear legal right to the relief sought. The concurrence also stated that a temporary injunction requires a likelihood of success on the merits as the first of four criteria.
Precedential value
Published Oklahoma Supreme Court decision; the per curiam order states the mandamus disposition, while separate concurrences provide additional reasoning.
Parties
Greenwood Centre, Ltd., John Hope Franklin Center for Reconciliation, Inc., Shannon Martin, Bim Stephen Bruner v. Rebecca Brett Nightingale, Judge of the District Court in and for Tulsa County
Disposition
writ_denied

Topics

writ of certiorariappellate jurisdictionappellate procedureinjunctionsremedies

Practice areas

civil procedureappellate procedureremediesconstitutional lawmunicipal law

Questions Presented

  1. Whether the Oklahoma Supreme Court should assume original jurisdiction over petitioners' application for extraordinary relief.
  2. Whether petitioners established a clear legal right to a writ of mandamus requiring social-distancing protocols for the proposed rally.
  3. Whether petitioners demonstrated a likelihood of success on the merits sufficient to support temporary injunctive relief.

Holdings

  1. The Court denied petitioners' application to assume original jurisdiction because petitioners failed to establish a clear legal right to the requested relief.

Key quotations

Petitioners cannot establish the necessary elements for a writ of mandamus, specifically that Petitioners possess a clear legal right to the relief they seek. (order)
The OURS Plan is permissive, suggestive and discretionary. (Combs, J. concurring, ¶ 1)

Factual background

Petitioners sought to prevent or restrict a June 20, 2020 presidential campaign rally at the BOK Center unless social-distancing protocols were implemented. Oklahoma's Open Up and Recover Safely Plan stated that entertainment venues had discretion to determine whether and when to apply social-distancing measures. The Governor's and Tulsa Mayor's executive orders presented to the Court did not impose a mandatory social-distancing requirement for the event.

Procedural history

The petition was presented directly to the Oklahoma Supreme Court. The Court denied the application to assume original jurisdiction because petitioners could not establish a clear legal right to the requested mandamus relief. A concurring writing explained that the applicable executive orders and the Open Up and Recover Safely Plan made social-distancing measures discretionary rather than mandatory.

Court Document

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