LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM.

2025 OK 87
CourtSupreme Court of Oklahoma
DecidedNovember 25, 2025
Docket122806
StatusPublished

This text of 2025 OK 87 (LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM.) 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.

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LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM., 2025 OK 87 (Okla. 2025).

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LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM.
2025 OK 87
Case Number: 122806
Decided: 11/25/2025
Correction Order: 12/8/2025
THE SUPREME COURT OF THE STATE OF OKLAHOMA


Cite as: 2025 OK 87, __ P.3d __

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



JAMES LAWSON, Plaintiff/Appellant,
v.
LeFLORE COUNTY DETENTION CENTER PUBLIC TRUST SECURITY COMMISSION, Defendant/Appellee.

APPEAL FROM THE DISTRICT COURT OF LeFLORE COUNTY
OKLAHOMA, HONORABLE JONATHAN SULLIVAN

0 The trial court granted Defendant's Motion for Summary Judgment, concluding that a jail trust formed pursuant to 60 O.S.2022, § 176et seq. and 19 O.S.2022, §§ 904.251 O.S.2022, § 24A.351 O.S.2022, § 24A.8

PREVIOUSLY RETAINED ON THIS COURT'S OWN MOTION;
SUMMARY JUDGMENT OF THE TRIAL COURT REVERSED;
REMANDED FOR FURTHER PROCEEDINGS.

Lysbeth George and Jennifer E. Jackson, LIZ GEORGE & ASSOCIATES, PLLC, Oklahoma City, Oklahoma, for Plaintiff/Appellant.

Howard T. Morrow and Jordan L. Miller, COLLINS, ZORN & WAGNER, P.L.L.C., Oklahoma City, Oklahoma, for Defendant/Appellee.

COMBS, J.:

1 The trial court plaintiff, James Lawson (Lawson), appeals the grant of summary judgment to the trial court defendant, LeFlore County Detention Center Public Trust (Jail Trust).

I. FACTS AND PROCEDURAL HISTORY

2 Lawson, is a bail bondsman and owner of Lawson Bail Bonds. On August 7, 2023, Lawson's ex-wife, Amber Lawson, went to the LeFlore County Detention Center (jail), which is under the control of Jail Trust. She went to the jail to bond out two inmates. The procedure was allegedly taking an unusually long time to execute and she asked the jailer why it was taking so long. The jailer allegedly yelled at her and cursed at her. She phoned Lawson who heard yelling over the phone. The inmates were then released about 15 to 20 minutes later.

¶3 On August 8, 2023, Lawson requested specific public records from the Jail Trust pursuant to the Oklahoma Open Records Act (ORA), 51 O.S.2022, §§ 24A.1et seq. He requested:

1. All audio and video footage pertaining to the bonding and release of Donald Robinson and Kevin Wiley on the date August 7, 2023, during the time frame 4:15 pm to 6:45 pm. Please also include all communication within the same specified time frame including but not limited to emails, text messages, or written correspondence, involving Amber Lawson, James Lawson or Lawson Bail Bonds.
2. A copy of the LeFlore County Detention Center policies and procedures.
3. The names of all employees working at the LeFlore County Detention Center during the specified time frame.

On August 28, 2023, a lawyer representing Lawson Bail Bonds sent a follow-up letter noting her client had not received a response from the Jail Trust and setting a deadline of September 1, 2023, for the Jail Trust to make such records available.

¶4 The Jail Trust responded to the request by letter dated September 6, 2023. The letter indicates the Jail Trust contacted Lawson on September 1, 2023, to acknowledge the records request. The letter states a review of the August 8, 2023, request was undertaken to determine what records existed and what records are subject to release under the ORA. It then informed Lawson that not all "law enforcement records" are available under the ORA, citing 51 O.S.2022, § 24A.8

¶5 On September 22, 2023, Lawson filed a Petition for Declaratory and Injunctive Relief for Violation of the Oklahoma Open Records Act and Writ of Mandamus in the District Court for LeFlore County. Lawson asserted the Jail Trust is a "public body" as defined under the ORA and the requested records are "records" as defined under the ORA. He further alleged the Jail Trust is not a "law enforcement agency" as defined in the ORA, that the disclosures and exceptions applicable to law enforcement agencies in section 24A.8 do not apply, and that the Jail Trust, therefore, wrongly refused a valid ORA request to make such records available. The Jail Trust answered, stating it was a public body but that it fell under the definition of "law enforcement agency" and that disclosure of requested information was therefore not mandatory but instead discretionary under the ORA. It based its claim at least partly on the fact that a county jail operated by a public trust has the same duties as a jail operated by the county sheriff.

¶6 Both parties filed motions for summary judgment and responses. Both sides claimed there were no genuine issues of material fact that would prevent summary judgment. Lawson alleged it is undisputed that the Jail Trust denied his legitimate records request under the ORA and, therefore, summary judgment should be awarded to him. The Jail Trust claimed it had discretion as a law enforcement agency under the ORA to decide whether to release the requested records that existed; therefore, it did not violate the ORA by denying the request for such records.

¶7 On December 4, 2024, the district court held a hearing on the competing motions. A Journal Entry of Judgment was filed on December 19, 2024, granting Jail Trust's motion for summary judgment. Lawson timely appealed on January 17, 2025. Lawson raises four issues on appeal: (1) whether the trial court erred in determining the Jail Trust is a "law enforcement agency" under the ORA; (2) whether the trial court erred in determining that the Jail Trust qualifies as a "public body charged with enforcing state or local criminal law and initiating criminal prosecutions" under 51 O.S.2022, § 24A.3

¶8 On January 31, 2025, this Court retained the matter on its own motion to address, as a matter of first impression, whether the Jail Trust qualifies as a "[l]aw enforcement agency" under the ORA as defined at 51 O.S.2022, § 24A.3

II. STANDARD OF REVIEW

9 While summary judgment proceedings require the trial court to examine factual matters, the trial court's role is limited to determining whether any genuine issues of material fact exist and, ultimately, whether a party is entitled to judgment as a matter of law. Carmichael v. Beller, 1996 OK 48914 P.2d 1051id., and we review it de novo to determine whether the trial court properly granted summary judgment, Citizens Against Taxpayer Abuse, Inc. v. City of Oklahoma City, 2003 OK 6573 P.3d 871de novo review, the court exercises plenary, independent, and nondeferential authority. Id.

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2025 OK 87, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawson-v-leflore-co-detention-center-public-trust-security-comm-okla-2025.