## Facts

- Oklahoma enacted Senate Bill 1062 (SB 1062), a comprehensive reform of the state’s workers’ compensation laws.
- SB 1062 repealed the existing Workers’ Compensation Code and replaced it with multiple new statutory schemes, including:
  - the Administrative Workers’ Compensation Act (an administrative adjudication system);
  - the Oklahoma Employee Injury Benefit Act (allowing certain employers to opt out and provide alternative benefit plans with internal review);
  - a Workers’ Arbitration Compensation Act (governing arbitration agreements for injury claims); and
  - a Workers’ Compensation Court of Existing Claims (addressing injuries arising before a specified date).
- Two legislators and a firefighters’ organization filed an original action challenging SB 1062’s constitutionality.
- The Oklahoma Supreme Court assumed original jurisdiction to decide the constitutional challenge.

## Issues

1. Whether SB 1062 violates Okla. Const. art. 5, § 57 by embracing more than one subject in a single legislative act.
2. Whether the court should address additional constitutional challenges to particular SB 1062 provisions (including due-process and equal-treatment-type objections) if the act fails the single-subject rule.
3. If SB 1062 violates the single-subject rule, whether the act is severable or must be invalidated in its entirety.

## Decision

- The Oklahoma Supreme Court held SB 1062 violated the single-subject rule of Okla. Const. art. 5, § 57.
- The court concluded SB 1062 combined multiple distinct legislative subjects—administrative adjudication, an opt-out benefit regime, a separate arbitration framework, and a court for existing claims—within one bill.
- The court declared SB 1062 unconstitutional in toto and did not sever individual components.
- The court declined to decide other constitutional attacks on specific provisions because the single-subject defect disposed of the case.

## Legal Principles

- Legislative enactments are presumed constitutional, and courts enforce statutes unless they clearly conflict with the constitution.
- Okla. Const. art. 5, § 57 requires a legislative act to embrace only one subject, clearly expressed, to prevent logrolling and surprise.
- Separate provisions may be included in one act only if they are germane, relative, and cognate to a single general subject; a broad theme cannot justify bundling independent policy schemes.
- When a single-subject violation infects an act structured as an interdependent package, severance may be inappropriate, and complete invalidation may be required.
- Courts may resolve a constitutional challenge on procedural grounds without reaching additional substantive constitutional objections.

## Conclusion

The Oklahoma Supreme Court invalidated SB 1062 in its entirety because it combined multiple distinct workers’ compensation policy schemes in one bill, violating the state constitution’s single-subject requirement, and the court therefore did not reach challenges to individual provisions on other constitutional grounds.


Coates v. Fallin, 316 P.3d 924 (Okla. 2013)