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Manhart v. Burris

Supreme Court of Oklahoma
618 p.2d 945, 1980 Okla. LEXIS 363, 1980 OK 154 (1980)
ELI5:

Rule of Law:

When two courts have concurrent jurisdiction over the same subject matter, the court in which the action is first filed acquires exclusive jurisdiction over the case to the exclusion of the other.


Facts:

  • Melba Manhart filed a petition for divorce against Peter Manhart in the District Court of Delaware County.
  • Seven minutes after Melba Manhart's filing, Peter Manhart filed his own petition for divorce against her in the District Court of Cherokee County.
  • Summons for the Delaware County action was issued at the time of filing and served on Peter Manhart on the same day, July 21.
  • Summons for the Cherokee County action was issued and served on Melba Manhart on August 13.

Procedural Posture:

  • In the Cherokee County action filed by Peter Manhart, Melba Manhart filed a special appearance and motion to quash, arguing the court lacked jurisdiction due to her prior filing in Delaware County.
  • The District Court of Cherokee County held a hearing and determined that venue was proper in its jurisdiction.
  • The District Court of Delaware County held a separate hearing and also determined venue was proper in its jurisdiction.
  • Both Melba Manhart and Peter Manhart initiated original proceedings in the Oklahoma Supreme Court, each seeking a writ of prohibition to halt the proceedings in the court where the other had filed.

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Issue:

When two divorce actions involving the same parties are filed in two different courts of competent jurisdiction, does the court where the action was filed first acquire exclusive jurisdiction over the matter?


Opinions:

Majority - Hargrave, J.

Yes. When two courts have concurrent jurisdiction, the first court to acquire jurisdiction will retain it to the exclusion of the other. The court adheres to an 'unbroken line of decisions' establishing this 'first-to-file' rule as a means of resolving jurisdictional conflicts. This principle provides a clear, efficient, and speedy standard that minimizes the need for appellate intervention, which is particularly valuable in domestic relations cases where venue may be proper in multiple jurisdictions. Because Melba Manhart filed her petition in Delaware County seven minutes before Peter Manhart filed his in Cherokee County, the Delaware County court acquired exclusive jurisdiction. The court also held that a subsequent hearing on venue in Delaware County was invalid due to a lack of proper notice to Peter Manhart, and ordered that issue to be reheard with proper notice, but this did not divest the Delaware County court of its primary jurisdiction.



Analysis:

This opinion solidifies the 'first-to-file' rule, or priority of jurisdiction doctrine, in Oklahoma. It establishes a bright-line rule that prioritizes temporal filing over any other factor when courts have concurrent jurisdiction. This promotes judicial efficiency and predictability by preventing parties from forum shopping or engaging in protracted litigation over which court should hear a case. The decision makes it clear that even a very short time difference in filing is dispositive, reinforcing the 'race to the courthouse' dynamic in situations where venue is proper in multiple locations.

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