DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma

CourtSupreme Court of Oklahoma
DecidedApril 7, 2026
Docket122686
StatusPublished
Cited by1 cases

This text of DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma (DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma) 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
DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma, (Okla. 2026).

Opinion

OSCN Found Document:DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma

DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma
2026 OK 20
Case Number: 122686
Decided: 04/07/2026
THE SUPREME COURT OF THE STATE OF OKLAHOMA


Cite as: 2026 OK 20, __ P.3d __

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



DON KEENAN, Plaintiff/Appellee,
v.
TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma, Defendant/Appellant.

APPEAL FROM THE DISTRICT COURT FOR OKLAHOMA COUNTY

¶0 Plaintiff filed suit in in the District Court and alleged the Energy Discrimination Elimination Act of 2022 (74 O.S. §§ 1200174 O.S. §§ 12001

JUDGMENT OF THE DISTRICT COURT AFFIRMED IN PART

Collin R. Walke, Hall Estill, Oklahoma City, Oklahoma, for Plaintiff/Appellee.

Gary M. Gaskins, II, and Zach West, and Will Flanagan, Office of the Oklahoma Attorney General, Oklahoma City Oklahoma, for Defendant/Appellant.

T. Matthew Smith, Criterion Legal, Oklahoma City, Oklahoma, for amicus curiae Oklahoma Retirees Association, in support of Plaintiff/Appellee.

Rachel L. Fried and Victoria Nugent, Washington, D.C., Democracy Forward Foundation, for amicus curiae Oklahoma Retirees Association, in support of Plaintiff/Appellee.

Ashley E. Quinn and Craig D. Martin, Morrison & Foerster, LLP, San Francisco, California, for amicus curiae Ceres, Inc., in support of Plaintiff/Appellee.

EDMONDSON, J.

¶1 We conclude the appeal may proceed based upon the appellate briefs and submission of the appeal to the Court before Keenan's death. We conclude Keenan, a retired employee who had previously made contributions to, and later received benefits from, the Oklahoma Public Employees Retirement System, possessed standing to seek injunctive relief in the District Court. We conclude the Energy Discrimination Elimination Act of 2022 (EDEA) (74 O.S.Supp.2025 §12001

I. THE CONTROVERSY

¶2 Keenan filed suit in 2023 claiming the Energy Discrimination Elimination Act of 2022 (74 O.S. §12001

¶3 Keenan's petition alleged the Act violated five provisions of the Oklahoma Constitution, Art. II, §6 (barrier to court access), Art. II, §7 (due process), Art. II, §22 (freedom of speech), Art. V, §46 (special law prohibition), and Art. XXIII, §12 (exclusive purpose for trust). Keenan requested a temporary restraining order and a temporary injunction. The trial court granted a temporary injunction to preserve the status quo.

¶4 The District Court sustained Keenan's requests for partial summary judgment by orders filed September 20, 2024, October 29, 2024. The trial court's order filed September 20, 2024, made its previous temporary injunction a permanent injunction and prevented the Treasurer from enforcing the Act. The trial court concluded the Act violated: (1) Okla. Const. Art. XXIII § 12 (exclusive purpose of benefits clause for the public retirement system),

¶5 The Treasurer appealed the trial court's order, and this Court retained the appeal. Before addressing the merits of the Treasurer's arguments challenging the trial court's order, we must first address a procedural issue raised by the parties.

II. Death of Appellee After Submission of the Appeal

¶6 A motion to retain the appellate cause in the Supreme Court was granted in December of 2024, and assigned to the Supreme Court for an appellate decision on January 16, 2025. Motions concerning the appellate record, extensions of time, and requests for briefing and appearances of amici curiae were filed. Treasurer filed a motion for a briefing schedule. The Court set a briefing schedule for the parties but specifically excluded amici curiae briefs. The Court then suspended briefing on the merits prior to briefs being filed. Appellee's counsel filed a "notice of suggestion of death" stating the death of appellee and included a motion for substitution.

¶7 The Court invited briefs on the effect of Keenan's death on the appeal. Keenan's counsel suggested no substitution for Keenan was necessary. Keenan's counsel also suggested that if a substitution was necessary, then an individual, unnamed by counsel's filing, could be added as a substitute appellee with the Court's approval. The motion for substitution did not address the unnamed individual's specific cognizable legal interest in the litigation or in Keenan's legal interests. Treasurer suggested Keenan's counsel had no client before the Court, and that filings by Keenan's counsel were improper. Counsel for both parties suggest a lack of recent express authority on proper procedure for appellate substitution after a party's death.

¶8 Historically, a defendant could file a plea in abatement and plead a "plaintiff not in rerum natura (plaintiff not "in existence" or not "in the world [or things], of nature").

¶9 Current appellate practice and procedure makes direct appellate review of a judgment or appealable order a part of, or continuation of, the "same trial court case." 12 O.S.2021 § 1052

¶10 Treasurer argues the Court may apply 12 O.S. §202512 O.S. §1080

The motion for substitution may be made by any party or by the successors or representatives of the deceased party . . . Unless the motion for substitution is made within ninety (90) days of service of the statement of death, the action shall be dismissed without prejudice as to the deceased party . . .
In case of any transfer of interest, the action may be continued by or against the original party, unless the court upon motion directs the person to whom the interest is transferred to be substituted in the action or joined with the original party.

Treasurer argues a 12 O.S. §2025required for the Court to adjudicate this appeal.

¶11 In Campbell v. Campbell, 1994 OK 84878 P.2d 103712 O.S. §202512 O.S. §2025Id. ¶19, 878 P.2d at 1041-42. However, guidance from F.R.C.P. 25 has limited application since appellate substitution of a party in a federal appellate court is not by F.R.C.P. 25, but Federal Rule of Appellate Procedure 43 ("Substitution of Parties"). We note Rule 43 contains language similar to language in Rule 25.

¶12 Treasurer argues that if a proper substitution does not occur, then Keenan's underlying trial court cause of action adjudicated by the trial court must have abated upon death of appellee during the appeal. Treasurer states he previously objected to the legal standing of Keenan. Treasurer states he must have an opportunity to object to the legal standing of any individual offered as a substitute appellee for Keenan.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Davis v. Burke
179 U.S. 399 (Supreme Court, 1900)
Bell v. Bell
181 U.S. 175 (Supreme Court, 1901)
Streitwolf v. Streitwolf
181 U.S. 179 (Supreme Court, 1901)
Hayes v. Brookwood Hosp.
572 So. 2d 1251 (Supreme Court of Alabama, 1990)
Bailey v. Campbell
862 P.2d 461 (Supreme Court of Oklahoma, 1992)
Farmers Insurance Gr. v. District Court of SEC. JD
507 P.2d 865 (Supreme Court of Colorado, 1973)
Palmer v. Belford
527 P.2d 589 (Supreme Court of Oklahoma, 1974)
Akin v. Missouri Pacific Railroad
1998 OK 102 (Supreme Court of Oklahoma, 1998)
Campbell v. Campbell
1994 OK 84 (Supreme Court of Oklahoma, 1994)
Matter of Estate of Crowl
737 P.2d 911 (Supreme Court of Oklahoma, 1987)
In Re House Bill No. 145
237 P.2d 624 (Supreme Court of Oklahoma, 1951)
Kolp v. State Ex Rel. Commissioners of the Land Office
312 P.2d 483 (Supreme Court of Oklahoma, 1957)
Brandon v. Ashworth
1998 OK 20 (Supreme Court of Oklahoma, 1998)
Hadnot v. Shaw
1992 OK 21 (Supreme Court of Oklahoma, 1992)
Reherman v. Oklahoma Water Resources Board
1984 OK 12 (Supreme Court of Oklahoma, 1984)
Independent School District No. 9 v. Glass
1982 OK 2 (Supreme Court of Oklahoma, 1982)
State Ex Rel. Blankenship v. Freeman
440 P.2d 744 (Supreme Court of Oklahoma, 1968)
Mullis v. Bone
238 S.E.2d 748 (Court of Appeals of Georgia, 1977)
Amoco Production Co. v. Lindley
1980 OK 6 (Supreme Court of Oklahoma, 1980)
Branch Trucking Co. v. State Ex Rel. Oklahoma Tax Commission
801 P.2d 686 (Supreme Court of Oklahoma, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
DON KEENAN v. TODD RUSS, in his capacity as the Treasurer of the State of Oklahoma, Counsel Stack Legal Research, https://law.counselstack.com/opinion/don-keenan-v-todd-russ-in-his-capacity-as-the-treasurer-of-the-state-of-okla-2026.