Elaine Desouza Gladstone, as Special Administratrix of the Estate of Martin John Gladstone, and as the Widow Of…

Summary

The Supreme Court of Oklahoma held that § 155(14) of the Governmental Tort Claims Act — which bars tort claims against the state or its political subdivisions for on-the-job injuries or death covered by workers' compensation while leaving other claimants free to sue — violates neither the equal protection guarantees of the Fourteenth Amendment and the Oklahoma Constitution nor the due process clauses of both constitutions. Because the exclusion is economic legislation resting on no suspect classification and impinging no fundamental right, rational-basis review governed, and the court found a rational basis in the legislature's objective of protecting the public fisc by limiting recoverability for public wrongs, declining to adopt the Minnesota solution striking down a like exemption. The court also rejected nonconstitutional attacks premised on fairness, the collateral source rule, and public safety, reiterating that courts may not invalidate legislation merely because it appears unwise or inequitable. On certiorari, the Court of Civil Appeals' opinion was vacated and the trial court's summary judgment for the school district was affirmed; all justices concurred.