## Facts

- Sandra Ladra, a homeowner in Prague, Oklahoma, alleged she suffered personal injuries during a 5.0 magnitude earthquake on November 5, 2011.
- While Ladra was inside her home, shaking caused rock facing from a two-story fireplace and chimney to fall into the living room, striking and injuring her knees and legs.
- Ladra sought damages exceeding $75,000 for her injuries.
- Ladra sued New Dominion, LLC, Spess Oil Company, and John Does 1–25, alleging their wastewater injection and disposal practices proximately caused the earthquake and her injuries.
- Defendants operated wastewater injection wells in and around Lincoln County and other parts of central Oklahoma during a period of increased earthquake frequency and severity in the state.

## Issues

1. Whether the Oklahoma Corporation Commission has exclusive jurisdiction over a private tort action seeking compensatory and punitive damages for personal injuries allegedly caused by wastewater injection operations.
2. Whether the district court retains jurisdiction to adjudicate causation, liability, and damages for such personal-injury claims.

## Decision

- The Oklahoma Supreme Court reversed the district court’s dismissal for lack of jurisdiction and remanded for further proceedings.
- The Court held that jurisdiction over Ladra’s personal-injury tort claims lies in the district court, not exclusively in the Oklahoma Corporation Commission.
- The Court treated the action as a private claim for money damages based on past alleged tortious conduct, rather than a request for prospective operational regulation of wells.

## Legal Principles

- The Oklahoma Corporation Commission is a regulatory agency with limited adjudicatory authority derived from the Oklahoma Constitution and statutes; it is not a court of general jurisdiction for private tort damages.
- District courts retain authority to hear common-law tort claims arising from oil and gas activities, including claims requiring proof of proximate cause and damages between private parties.
- A comprehensive regulatory scheme does not, without clear legislative direction, displace common-law remedies for personal injury.
- The presence of technical or specialized issues within a tort case does not, by itself, divest district courts of jurisdiction in favor of exclusive agency authority.

## Conclusion

The Oklahoma Supreme Court held that a private plaintiff alleging personal injuries from an earthquake purportedly induced by wastewater injection may pursue tort remedies in district court, and the Oklahoma Corporation Commission’s regulatory role does not provide exclusive jurisdiction over such damages claims.


Ladra v. New Dominion, L.L.C., 353 P.3d 529 (Okla. 2015)