Cactus Drilling Company, L.L.C. v. The Honorable Kory Kirkland, and Faulkner

Summary

The Oklahoma Supreme Court issued writs of prohibition and mandamus concerning a district court action arising from a workplace injury. The Court held that the employee's prior pursuit of workers' compensation benefits barred his later gross-negligence claim in district court under the Oklahoma Administrative Workers' Compensation Act's exclusivity and anti-claim-splitting provisions. The Court ordered the district court to refrain from enforcing its September 11, 2025 judgment and to dismiss the claims against Cactus Drilling Company, L.L.C.

Holdings

1. An employee who has maintained a workers' compensation action by instituting, pursuing, and continuing the claim and receiving benefits cannot later maintain an intentional-tort or gross-negligence action in district court, even if the workers' compensation claim is later dismissed.
2. Subrogation could not preserve Faulkner's district-court claim or eliminate the double-recovery problem because Cactus Drilling or its workers' compensation carrier could not bring a subrogation action against Cactus Drilling itself, and no statutory provision authorized recovery of the full benefits already paid.

Questions Presented

1. Whether an employee who filed a workers' compensation claim, invoked the Workers' Compensation Commission's jurisdiction, pursued the claim, and received benefits may later maintain a gross-negligence or intentional-tort action in district court after dismissing the workers' compensation claim.
2. Whether subrogation could preserve the district-court claim or prevent double recovery where the employer or its carrier paid the workers' compensation benefits.

Disposition

writ_granted