Oklahoma Supreme Court allows negligence suit against Freeman Health System to proceed, affirms dismissal of out-of-state doctor

The Oklahoma Supreme Court on Sept. 30, 2025 ruled that a trial court should reassess whether a plaintiff—s malpractice claims "relate to" Freeman Health System—s contacts with Oklahoma, vacating an intermediate appellate opinion and remanding the matter for further proceedings. The court simultaneously affirmed the district court—s dismissal of claims against Dr. Gulshan Upal for lack of personal jurisdiction and reversed the dismissal of Freeman Health System, allowing discovery and additional proceedings on whether Freeman—s Oklahoma ties are sufficiently related to the claims.

The case arises from plaintiff Whitney Bridal—s 2021 medical care: after repeated emergency visits in April 2021 she traveled to Freeman Health System in Joplin, Missouri, where clinicians ultimately diagnosed dural venous sinus thrombosis, hydrocephalus and an altered mental state. The opinion summarizes that Bridal was later transferred to KU Medical Center for an emergency thrombectomy and required long-term acute care, and that she filed suit in Ottawa County, Oklahoma alleging negligent diagnosis, treatment and discharge by multiple providers.

The defendants Freeman Health System and Dr. Gulshan Upal moved to dismiss under Rule 12(b)(2), arguing Oklahoma courts lacked personal jurisdiction. The district court sustained that motion, and the Oklahoma Court of Civil Appeals affirmed. On review the Supreme Court applied the two-part specific-jurisdiction framework explained in Ford Motor Co. v. Montana Eighth Judicial Dist. Court and concluded the district court had addressed only whether the suit "arose out of" the defendants— forum contacts, not whether the suit "relates to" those contacts as the Ford test requires.

The court identified evidence Bridal had presented tying Freeman to Oklahoma: Freeman is registered to conduct business in Oklahoma; leases buildings and operates medical facilities in Grove and Miami, Oklahoma; operates and staffs a clinic and a casino in Quapaw; employs Oklahoma residents; lists Oklahoma office and physician information on its website; advertises its Missouri facilities on outlets that reach northeast Oklahoma; maintained multiple billboards in Oklahoma; and saw thousands of patients with Oklahoma addresses at its Joplin hospital. The opinion says these contacts may warrant further discovery to determine whether Bridal—s claims relate to Freeman—s Oklahoma contacts.

At the same time, the court found the record insufficient to establish personal jurisdiction over Dr. Upal. "The undisputed evidence demonstrates that Dr. Upal does not live in Oklahoma, does not own property in Oklahoma, does not practice medicine in Oklahoma and does not see any patients in Oklahoma," the opinion states, and a submitted exhibit purporting to show the doctor admitted to an Oklahoma hospital was found nearly illegible and insufficient to carry Bridal—s burden. The Supreme Court therefore affirmed dismissal of Bridal—s claims against Dr. Upal for lack of personal jurisdiction.

The court—s disposition vacated the Court of Civil Appeals opinion, affirmed in part, reversed in part and remanded for further proceedings consistent with its opinion. The court specifically directed the trial court to determine whether Bridal is entitled to additional discovery concerning Freeman—s contacts with Oklahoma and ultimately whether her claims "relate to" those contacts.

The opinion cites Oklahoma—s long-arm statute and federal due-process precedents including International Shoe and Ford Motor Co. v. Montana, and reiterates the two-step inquiry for specific jurisdiction: (1) whether the defendant purposefully availed itself of the forum and (2) whether the plaintiff's claims arise out of or relate to the defendant's forum contacts, and finally whether exercising jurisdiction would be fair and reasonable. The opinion notes that the district court erred by stopping after the first half of the Ford inquiry and ordered further proceedings on the second half.

The case returns to the trial court for further factfinding; the Supreme Court did not predecide whether Freeman is subject to jurisdiction in Oklahoma, stating that additional discovery and analysis are appropriate. The opinion is not yet released for publication and is subject to revision.