Rev. Dr. Mitch Randall, et al. v. Lindel Fields, et al.

2025 OK 91 · Supreme Court of the State of Oklahoma · December 16, 2025 · No. 123237

Summary

The Oklahoma Supreme Court assumed original jurisdiction over a challenge to the 2025 Oklahoma Academic Standards for Social Studies. The Court held that the standards were adopted in violation of the Oklahoma Open Meeting Act because the version approved by the State Board of Education was not properly disclosed before the meeting. It granted declaratory relief, dissolved the stay, withheld mandamus relief without prejudice, and concluded that the 2019 standards remained valid until replaced.

Holdings

  1. The Oklahoma Supreme Court assumed original jurisdiction because the controversy involved the validity of statewide public-school standards, presented a publici juris issue, and warranted immediate statewide judicial resolution and judicial economy.
  2. The State Board violated 25 O.S. 2021, § 311 by approving a materially revised version of the 2025 Standards without providing the public with at least twenty-four hours' advance notice of the version and substantive content to be considered.
  3. The Legislature's silent acquiescence and deemed approval of the 2025 Standards did not cure the State Board's prior violation of the Open Meeting Act.
  4. The 2025 Oklahoma Academic Standards for Social Studies may not be enforced; the 2019 Standards remain in effect until the Board properly adopts new standards with subsequent legislative review. The Court withheld mandamus and denied injunctive relief without prejudice.

Questions Presented

  1. Whether the Oklahoma Supreme Court should assume original jurisdiction over the challenge to the 2025 Oklahoma Academic Standards for Social Studies.
  2. Whether the State Board of Education violated the Oklahoma Open Meeting Act by approving standards that were materially different from the publicly posted version without providing the required advance notice.
  3. Whether the Legislature's deemed approval or silent acquiescence cured the Board's prior Open Meeting Act violation.
  4. What declaratory, injunctive, and mandamus relief was appropriate after the Court found an Open Meeting Act violation.

Disposition

other

Cases Cited (12)

  • State ex rel. Freeling v. Ross, 1919 OK 257, 183 P. 918(followed)
  • Draper v. State, 1980 OK 117, 621 P.2d 1142(followed)
  • Dutton v. City of Midwest City, 2015 OK 51, 353 P.3d 532(followed)
  • Sanders v. Followell, 1977 OK 143, 567 P.2d 84(followed)
  • Democratic Party of Oklahoma v. Estep, 1982 OK 106, 652 P.2d 271(considered)
  • Ethics Commission of State of Oklahoma v. Cullison, 1993 OK 37, 850 P.2d 1069(followed)
  • Conoco, Inc. v. State Department of Health, 1982 OK 94, 651 P.2d 125(followed)
  • Independent School District No. 12 of Oklahoma County v. State ex rel. Board of Education, 2024 OK 39, 565 P.3d 23(followed)
  • Andrews v. Independent School District No. 29 of Cleveland County, 1987 OK 40, 737 P.2d 929(followed)
  • Fraternal Order of Police, Bratcher/Miner Memorial Lodge, Lodge No. 122 v. City of Norman, 2021 OK 20, 489 P.3d 20(followed)

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