Tyler Abbey, as Surviving Next of Kin and Personal Representative of the Estate of Deja Curtis, Deceased v. Baptist Health Services d/b/a Baptist Health Women’s Clinic - Fort Smith, a Foreign Corporation; Baptist Health Services d/b/a Baptist Health Family Clinic - South, a Foreign Corporation; Baptist Health d/b/a Baptist Health Medical Center — Little Rock, a Foreign Corporation; Mark J. Fowler, M.D.

CourtDistrict Court, E.D. Oklahoma
DecidedOctober 28, 2025
Docket6:25-cv-00123
StatusUnknown

This text of Tyler Abbey, as Surviving Next of Kin and Personal Representative of the Estate of Deja Curtis, Deceased v. Baptist Health Services d/b/a Baptist Health Women’s Clinic - Fort Smith, a Foreign Corporation; Baptist Health Services d/b/a Baptist Health Family Clinic - South, a Foreign Corporation; Baptist Health d/b/a Baptist Health Medical Center — Little Rock, a Foreign Corporation; Mark J. Fowler, M.D. (Tyler Abbey, as Surviving Next of Kin and Personal Representative of the Estate of Deja Curtis, Deceased v. Baptist Health Services d/b/a Baptist Health Women’s Clinic - Fort Smith, a Foreign Corporation; Baptist Health Services d/b/a Baptist Health Family Clinic - South, a Foreign Corporation; Baptist Health d/b/a Baptist Health Medical Center — Little Rock, a Foreign Corporation; Mark J. Fowler, M.D.) is published on Counsel Stack Legal Research, covering District Court, E.D. 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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Tyler Abbey, as Surviving Next of Kin and Personal Representative of the Estate of Deja Curtis, Deceased v. Baptist Health Services d/b/a Baptist Health Women’s Clinic - Fort Smith, a Foreign Corporation; Baptist Health Services d/b/a Baptist Health Family Clinic - South, a Foreign Corporation; Baptist Health d/b/a Baptist Health Medical Center — Little Rock, a Foreign Corporation; Mark J. Fowler, M.D., (E.D. Okla. 2025).

Opinion

EASTERN DISTRICT OF OKLAHOMA ,._. vm (1) TYLER ABBEY, as Surviving Next of Kin ) and Personal Representative of the Estate of ) OCT 28 2025 DEJA CURTIS, Deceased, ) BONNIE BACKLER Plaintiff, ) Honuty Chane ) Vv. ) 25-CV-123-JAR ) (1) BAPTIST HEALTH SERVICES d/b/a ) BAPTIST HEALTH WOMEN’S CLINIC - ) FORT SMITH, a Foreign Corporation; ) ) (2) BAPTIST HEALTH SERVICES d/b/a ) BAPTIST HEALTH FAMILY CLINIC - SOUTH, ) a Foreign Corporation; ) ) (3) BAPTIST HEALTH d/b/a BAPTIST ) HEALTH MEDICAL CENTER — LITTLE ROCK, ) a Foreign Corporation; ) ) (4) MARK J. FOWLER, M.D., ) ) Defendants. )

OPINION AND ORDER This case arises from tragedy and returns to a question as old as the law itself: whether equity, grounded in Oklahoma’s promise of open courts, may overcome the boundaries of another state’s law, or whether this Court must hold firm to the rule as it is written.

A woman from Oklahoma sought care just across the state line in Arkansas. She trusted her doctors, fought her illness, and was lost too soon. Her family now turns to this Court, invoking Oklahoma’s promise of access to justice, and asks

whether their inability to satisfy Arkansas’s procedural requirements, | missed step in the process, should nonetheless foreclose their opportunity to be heard in their home-state forum.

The Defendants, all Arkansas medical providers, contend that the law leaves no room for discretion: a claim filed before legal authority to sue existed isino claim at all, and the limitations fixed by statute cannot yield to emotion or the borders between states. The question before the Court is narrow but consequential. It rests auihe point where equity yields to certainty, and where justice itself depends upon neonty to law.

I. FACTUAL AND PROCEDURAL BACKGROUND

Before the Court is Defendants’ Joint Motion to Dismiss or, in the Alternative, Transfer Venue (Dkt. No. 18), Plaintiff's Response in Opposition (Dkt. No. 33), and Defendants’ Reply (Dkt. No. 39). This case arises from the medical care provided to De’Ja Curtis r Baptist Health facilities in Fort Smith and Little Rock, Arkansas, between April we August 2021. (See Dkt. No. 18 at 2—3; Dkt. No. 2-17- Plaintiff's Petition.) Plaintiff alleges that Defendants failed to timely diagnose and treat cervical cancer, leading to the Curtis’ death in Oklahoma on February 13, 2023. (/d.; Dkt. No. 33 at 2.) Plaintiff first filed suit on April 28, 2028, in the Circuit Court of Sebastian County, Arkansas, asserting the same claims presented here. (See Dkt.|No. 2-2 — Arkansas Complaint). At that time, he had not yet been appointed personal □

representative of the Estate. The record reflects that appointment occurred on June 1, 2023, more than a month after the initial filing. (See Dkt. No. 2-2, Ex. 17 at 2; Dkt. No. 33 at 2.) Facing discovery challenges to his capacity, Plaintiff voluntarily dismissed the Arkansas action without prejudice on October 17, 2023. (See Dit No. 18 at 3.)

Nearly one year later, on October 16, 2024, Plaintiff filed a new bi in the District Court of Sequoyah County, Oklahoma, naming the same Arkansas Defendants and asserting identical allegations. (See Dkt. No. 18; Dkt. No. 2-17) Defendants timely removed the case to this Court on November 15, 2024, invoking diversity jurisdiction under 28 U.S.C. §§ 1332 and 1441. (See Dkt. No. 2,| Notice of Removal) On May 7, 2025, the parties filed executed consent forms, expressly indicating their consent to proceed before the undersigned United States Magistrate Judge pursuant to 28 U.S.C. § 636(c)(1) and Fed. R. Civ. P. 73(a). The Clerk patered a minute order confirming that “this case is deemed consented to the magistrate judge” and that the undersigned “will exercise complete jurisdiction through and including trial and entry of final judgment.” (See Dkt. No. 26.) A hearing on Defendants’ motion to dismiss was held on August 25, 2025. Counsel for all parties appeared and presented oral argument. mene were represented by Mark D. Wankum, Timothy G. Best, and Benjamin D,.. Jackson; Plaintiff was represented by Donald E. Smolen IT and Steven Lance mie Following

argument, the Court took the matter under advisement. (See Dkt. No. 43, Minutes of Hearing.) II GOVERNING LAW

A. Standard for a Motion to Dismiss

"To survive a motion to dismiss [under Rule 12(b)(6)], a complaint must contain sufficient factual matter, accepted as true, 'to state a claim to relief that spn on its face." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl, Corp. v. Twombly, 550 U.S. 554, 570 (2007)). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Jd. The question to be decided is "whether the complaint sufficiently alleges facts supporting all the elements necessary to establish an entitlement to relief under the legal theory proposed." Lane v. Simon, 495 F.3d 1182, 1186 (10th Cir. 2007) (internal quotations omittes) B. Substantive and Choice-of-Law Principles When jurisdiction rests on diversity, a federal court applies the substantive law of the forum state, including its choice-of-law principles. Oklahoma flow the “most significant relationship” test from Brickner_v. Gooden, 525 P.2d re (Okla. 1974), and the Restatement (Second) of Conflict of Laws § 175. The Court considers:

(1) where the injury occurred;

A

(2) where the conduct causing the injury occurred; (3) the domicile or place of business of the parties; and

(4) where the relationship between the parties was centered. Ill. ANALYSIS

A. Arkansas Law Governs Every operative fact in this record points to Arkansas. The stock acts of negligence occurred in Arkansas. The physicians and medical providers are hrkansas citizens, licensed and regulated under Arkansas law. The relationship between patient and provider was formed, governed, and completed there. Although Ms. Curtis was an Oklahoma resident and her death occurred in Oklahoma, the Restatement (Second) of Conflict of Laws § 175 provides that “the place where the injury occurs is the place where the force set in motion by the post first takes effect on the person,” not necessarily where death occurs. The mens acts alleged here took effect in Arkansas. Plaintiff relies on Brickner v. Gooden, 525 P.2d 632 (Okla. 1974), to argue that Oklahoma’s “open courts” policy should govern this action. The argument misreads both the decision and the factual record before this Court. In Brickner, the Oklahoma Supreme Court adopted the “most significant relationship” test from the Restatement (Second) of Conflict of Laws § 175. a at 635. The case involved an airplane owned, hangared, and registered in Oklahoma; both

the pilot and passenger were Oklahoma residents; and the flight viinae in and

was to return to Oklahoma. The crash occurred in Mexico. Jd. at 633-34. court concluded Oklahoma law controlled because Oklahoma had the ‘mina relationship to both the parties and the occurrence, while Mexico’s only contact was

as the location of the accident. Jd. at 636.

That holding does not support Plaintiffs position.

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Tyler Abbey, as Surviving Next of Kin and Personal Representative of the Estate of Deja Curtis, Deceased v. Baptist Health Services d/b/a Baptist Health Women’s Clinic - Fort Smith, a Foreign Corporation; Baptist Health Services d/b/a Baptist Health Family Clinic - South, a Foreign Corporation; Baptist Health d/b/a Baptist Health Medical Center — Little Rock, a Foreign Corporation; Mark J. Fowler, M.D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyler-abbey-as-surviving-next-of-kin-and-personal-representative-of-the-oked-2025.