BETTS V. TOYOTA

CourtSupreme Court of Oklahoma
DecidedApril 14, 2026
Docket122040
StatusPublished

This text of BETTS V. TOYOTA (BETTS V. TOYOTA) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BETTS V. TOYOTA, (Okla. 2026).

Opinion

OSCN Found Document:BETTS V. TOYOTA, et al.

BETTS V. TOYOTA, et al.
2026 OK 22
Case Number: 122040
Decided: 04/14/2026
THE SUPREME COURT OF THE STATE OF OKLAHOMA


Cite as: 2026 OK 22, __ P.3d __

NOTICE: THIS OPINION HAS NOT BEEN RELEASED FOR PUBLICATION. UNTIL RELEASED, IT IS SUBJECT TO REVISION OR WITHDRAWAL.



WAYNE BETTS and KRISTIN BETTS, Plaintiffs/Appellants,
v.
TOYOTA MOTOR CORPORATION, a foreign corporation; TOYOTA MOTOR NORTH AMERICA, INC., a foreign corporation; and TOYOTA MOTOR SALES, U.S.A., INC., a foreign corporation, Defendants/Appellees.

ON CERTIORARI FROM THE COURT OF CIVIL APPEALS, DIVISION II

¶0 Appellants sued a car manufacturer for products liability. The district court granted the manufacturer's motion for summary judgment, holding that Texas's statute of repose barred Appellants' claim. Appellants appealed, and the Court of Civil Appeals reversed, concluding Texas law did not apply. This Court granted certiorari. We hold that, under the facts and circumstances of this case, Texas has the most significant relationship to the occurrence and parties involved, and Texas's statute of repose bars Appellants' claim.

COURT OF CIVIL APPEALS' OPINION VACATED;
DISTRICT COURT'S JUDGMENT AFFIRMED.

Richard L. Denney, Lydia JoAnn Barrett, Russell T. Bowlan, and Jason Eric Robinson, Denney & Barrett, P.C., Norman, Oklahoma, for Appellants.

Mary Quinn Cooper, Andrew L. Richardson, and Katie G. Crane, McAfee & Taft, P.C., Tulsa, Oklahoma, for Appellees.

Winchester, J.

¶1 Appellants Wayne and Kristin Betts (collectively "Betts") appeal a summary judgment in favor of Appellees Toyota Motor Corporation, Toyota Motor North America, Inc., and Toyota Motor Sales, U.S.A., Inc. (collectively "Toyota"). The Betts brought a products liability claim against Toyota after Wayne Betts ("Husband") was injured in a single vehicle, rollover car accident while driving a 2002 Toyota Sequoia. The issue before this Court is whether Texas's statute of repose for products liability claims bars the Betts' claim. We answer this question in the affirmative, as Texas has the most significant relationship to the parties regarding the statute of repose's applicability in this products liability case.

FACTS AND PROCEDURAL HISTORY

¶2 Toyota designed the 2002 Sequoia in Japan and manufactured the vehicle in Indiana. On January 10, 2002, Toyota first sold the vehicle in Georgia. In 2015, the vehicle was resold to Husband's grandmother in Texas. After her passing in 2016, Husband retitled the vehicle in his name.

¶3 At the time of the accident, the Betts resided in Arlington, Texas.

¶4 The Betts asserted that they spent considerable time driving the vehicle in Oklahoma. For less than a year leading up to the accident, Husband worked as a frac hand and driver for Eco-Stim Energy Solutions, Inc. He traveled to Fairview, Oklahoma every two to four weeks for work, which required him to drive the subject vehicle and obtain a few oil changes while in Oklahoma.

¶5 On February 20, 2018, Husband picked up his brother-in-law around 2:30 a.m. and drove to Oklahoma to attend a work safety meeting. While driving in Fairview, Oklahoma, the vehicle lost traction due to icy road conditions. The Betts allege that, despite the vehicle clearly losing directional control, the electronic stability control failed to activate properly and did not correct the vehicle's path. As a result of the accident, Husband sustained injuries that left him paralyzed.

¶6 After the accident, Husband received medical care in Oklahoma for approximately one week. He then transferred to Baylor University Medical Center in Texas, where he received treatment for over two and a half months.

¶7 The Betts filed a products liability action against Toyota, alleging that the subject vehicle was defective. Toyota moved for summary judgment, arguing that Texas's 15-year statute of repose barred the Betts' claim. Toyota asserted that Texas law should apply because Texas had the most significant contacts to the parties and the accident. In response, the Betts argued that Oklahoma law should apply since Husband frequently traveled to Oklahoma for work and his injury occurred there. Relying on the most significant relationship test adopted by this Court in Brickner v. Gooden, 1974 OK 91525 P.2d 632

¶8 The Court of Civil Appeals ("COCA") reversed the district court's judgment. COCA applied both Brickner v. Gooden, which relied on § 145 of the Restatement (Second) of Conflict of Law, and Edwards v. McKee, 2003 OK CIV APP 5976 P.3d 73

STANDARD OF REVIEW

¶9 Summary judgment resolves issues of law, and we review a district court's grant of summary judgment de novo. U.S. Bank, N.A. ex rel. Credit Suisse First Boston Heat 2005--4 v. Alexander, 2012 OK 43280 P.3d 936de novo standard, we subject the record to a new and independent examination without regard to the district court's reasoning or result. Gladstone v. Bartlesville Indep. Sch. Dist. No. 30, 2003 OK 3066 P.3d 442U.S. Bank, 2012 OK 43280 P.3d at 939. If reasonable individuals could reach different factual conclusions under the evidentiary materials, summary judgment is improper. Id.

DISCUSSION

¶10 This products liability case involves a 2002 Toyota Sequoia that the Betts contend was defective. Toyota argues that Texas's statute of repose should apply, barring the Betts' claim. Texas law requires a claimant to "commence a products liability action against a manufacturer or seller of a product before the end of 15 years after the date of the sale of the product by the defendant." Tex. Civ. Prac. & Rem. § 16.012(b) (West 2025). Conversely, the Betts argue that the Court should apply Oklahoma law, which does not impose a statute of repose for products liability actions.

¶11 In Brickner v. Gooden, we adopted the Restatement's "most significant relationship" test for tort cases when there is a conflict of law. The plaintiffs in Brickner sought to recover for personal injuries resulting from an airplane crash that occurred in Mexico. 1974 OK 91525 P.2d at 634. The issue before the Court was whether the parties' rights and liabilities should be determined by the laws of Mexico or those of Oklahoma. The airplane operator argued that the law of the place of the injury should apply. However, the injured parties contended that the place having the most significant relationship with the occurrence and parties should apply. Id. ¶¶ 5-6, 525 P.2d at 634.

¶12 The Brickner Court expressly abandoned the lex loci delicti rule (which dictates that the law of the place of the wrong should apply) and held that the rights and liabilities of parties with respect to a specific tort issue shall be determined by the local law of the state with the most significant relationship to the occurrence and the parties. Id. ¶ 23, 525 P.2d at 637.

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