The Oklahoma Supreme Court recently ruled in the case of Thomas & Goza v. Liberty Mutual Insurance Company, reversing a lower court's decision that had granted summary judgment to plaintiff Maryann Thomas. The court's decision, filed on September 14, 2026, allows Liberty Mutual to withdraw admissions it had previously made regarding coverage for Thomas's injuries from a car accident. This ruling has implications for how requests for admissions are treated in legal proceedings.
Maryann Thomas was involved in a motor vehicle accident on October 6, 2020, and subsequently filed a lawsuit against Liberty Mutual Insurance Company seeking uninsured/underinsured motorist (UM/UIM) coverage for her injuries. The case, docket number 123547, arose from a dispute over whether Liberty Mutual's policy provided the necessary coverage. The case reached the Oklahoma Supreme Court after Liberty Mutual sought to withdraw admissions it had made due to a failure to respond to requests for admission.
The background of the case indicates that Thomas's attorney sent requests for admission to Liberty Mutual's previous attorney, Stephanie K. Corbett, on June 9, 2022. However, Corbett had left the firm, and Liberty Mutual's new attorneys were not aware of the pending requests. After a year, Thomas filed a motion for summary judgment, arguing that the requests had been deemed admitted due to Liberty Mutual's failure to respond. The trial court granted summary judgment to Thomas, leading Liberty Mutual to appeal.
The Oklahoma Supreme Court held that the trial court abused its discretion by denying Liberty Mutual's request to withdraw the admissions. The court found that allowing Liberty to withdraw the admissions would promote the presentation of the merits of the case. The ruling stated, "The central and dispositive issue in this case is whether the policy provided UM/UIM coverage for Thomas's injuries." The court emphasized that the admissions were critical to the summary judgment and that Liberty had valid reasons for not responding to the requests.
The court's ruling also noted that Thomas had not demonstrated any prejudice from allowing Liberty to withdraw the admissions. The court pointed out that Thomas had been aware that the issue of coverage would be contested at trial. This decision underscores the importance of ensuring that parties have the opportunity to present their cases fully, especially when procedural missteps occur.
The impact of this ruling is significant for both parties involved and for future cases. It clarifies that courts may allow the withdrawal of admissions under certain circumstances, particularly when the failure to respond was not due to negligence or misconduct by the party seeking to withdraw. This decision may encourage parties to be more vigilant in their handling of discovery requests and ensure that they are represented adequately throughout the litigation process.
Moving forward, this ruling sets a precedent that may influence how courts handle similar cases involving requests for admissions. It emphasizes the need for clear communication between attorneys and the importance of timely responses to discovery requests. Liberty Mutual now has the opportunity to contest the admissions and present its defense regarding the coverage issue.
As for what’s next, the case has been remanded back to the lower court with instructions to allow Liberty to withdraw the admissions. This means that the trial court will need to reconsider the summary judgment in light of Liberty's ability to contest the admissions. There is no indication in the court filing that this decision will be appealed further, but the case will continue in the lower court, allowing both parties to present their arguments regarding the insurance coverage.