Key Points
- The Oklahoma Supreme Court held 5-4 that Oklahoma courts have specific personal jurisdiction over Idaho-based Colyer Herefords and Angus Inc. in a suit over the care and death of a Hereford bull sold at the Cattlemen's Congress in Oklahoma City.
- The majority held that Colyer purposefully availed itself of Oklahoma by transporting the bull to the Oklahoma City auction and agreeing that the bull would spend half of each year in Oklahoma.
- Applying Ford Motor Co., the court held that the negligent-care claim relates to Colyer's Oklahoma contacts even though the alleged negligence occurred outside the state, and that the accounting claims arise directly from the ownership interest acquired at the auction.
- The court agreed with the trial court that Colyer is not subject to general jurisdiction in Oklahoma.
- Under 12 O.S. ยง 990A and Owens v. Owens, the 30-day appeal period ran from the October 28, 2025 filing of proof of service, so the appeal was timely and Colyer's motion to dismiss the appeal was denied.
The Oklahoma Supreme Court ruled 5-4 on Tuesday that two Oklahoma cattle ranchers may sue an Idaho breeder in Oklahoma over the death of a Hereford bull they bid $100,000 for at an Oklahoma City auction, even though the care they blame for the animal's death took place outside the state.
Justice Gurich, writing for the majority, held that Colyer Herefords and Angus Inc. made itself answerable in Oklahoma courts when it brought the bull to the state for sale and agreed that the animal would live there half of each year. The decision reverses a trial judge's dismissal of the suit by David Schrammel and Randy Ward. Chief Justice Rowe and Justices Winchester, Kane and Jett dissented.
The ruling applies the U.S. Supreme Court's 2021 decision in Ford Motor Co. v. Montana Eighth Judicial District Court, which held that claims against an out-of-state company may proceed where they "relate to" its activity in the forum state, even without a strict causal link. The majority applied that standard to negligence that occurred in another state because the claim concerned the same bull and the same deal struck at the Oklahoma sale.
Colyer is based in Bruneau, Idaho. In November 2021, Schrammel saw a promotional video of the bull, registered as C GKB Guardian 1015 ET, on Colyer's Facebook page and called the company several times. Under the arrangement, the ranchers would submit the winning $100,000 bid at the Cattlemen's Congress in Oklahoma City. In exchange, they would receive an ownership interest in Guardian, a one-fourth share of proceeds from sales of his semen, and a promise that he would spend at least half of each year in Oklahoma.
Colyer brought Guardian to the January 2022 sale, where the ranchers won the bid. The bull never returned to Oklahoma, and Colyer housed, fed and maintained him outside the state. In 2023 the company took Guardian to a national stock show in Denver. The ranchers allege that Colyer negligently prepared him for the show and overfed him, causing him to founder and develop chronic laminitis so severe that he was euthanized.
The ranchers sued in April 2025 over Guardian's care and death and sought an accounting of their share of the semen proceeds. Colyer moved to dismiss for lack of personal jurisdiction. The Oklahoma County District Court, with Don Andrews presiding, granted the motion in October 2025.
The Supreme Court agreed that Oklahoma lacks general jurisdiction, which lets a state's courts hear any claim against a defendant that is essentially at home there. Colyer has no offices, employees or operations in Oklahoma, the court noted, and its national advertising, 506 sale catalogs sent to the state and 43.5 head of cattle sold to Oklahoma buyers through its Idaho sale barn fell well short of the exceptional case required.
Specific jurisdiction, which covers claims tied to a defendant's own activities in the state, was a different matter. "Colyer did not merely enter a contract with Oklahoma residents or place Guardian into the stream of commerce with knowledge that the bull might eventually arrive in this State," Gurich wrote. "Colyer itself transported Guardian to Oklahoma and placed the bull in Cattlemen's Congress auction in Oklahoma City." Those contacts, together with the custody arrangement, "resulted from Colyer's own deliberate conduct and were neither random, isolated, nor fortuitous," the court held.
The court said the claims over the semen proceeds arise directly from the ownership interest acquired at the auction, while the negligent-care claim alleges conduct that destroyed the interests the deal created. "Although the allegedly negligent care occurred outside this State, specific jurisdiction does not require proof that the defendant's forum conduct directly caused the asserted injury," Gurich wrote. "Here, Colyer's Oklahoma contacts and Plaintiffs' claims concern the same bull, the same ownership arrangement, and the same continuing obligations."
The court also found that trying the case in Oklahoma would be fair. "Nothing in the present record demonstrates that requiring Colyer to defend the action in Oklahoma would be constitutionally unreasonable," Gurich wrote.
Justice Winchester, in a dissent joined by Justice Kane, wrote that the Oklahoma sale had nothing to do with the bull's death. "The fact that the bull was briefly in Oklahoma for a show and auction years before the alleged negligence is not relevant or connected to Plaintiffs' injury," Winchester wrote. "Plaintiffs could have submitted the winning bid for the bull at an auction held anywhere."
The dissent relied on the U.S. Supreme Court's 2017 decision in Bristol-Myers Squibb Co. v. Superior Court, which requires an affiliation between the forum and the underlying controversy. Colyer's advertising and its showing of cattle in Oklahoma "may show it purposefully availed itself of the Oklahoma market, but the injury alleged did not arise out of or relate to those actions," Winchester wrote.
Before reaching jurisdiction, the court denied Colyer's motion to dismiss the appeal as late. The trial court's order was filed Oct. 3, 2025, but no proof of service appeared in the record until Oct. 28. Colyer argued that the ranchers' Dec. 1 petition in error, the filing that starts an Oklahoma appeal, came "59 days after the appealable order was filed and served on them."
Applying the state's appeal-deadline statute and its 2023 decision in Owens v. Owens, the court held that the 30-day clock began on Oct. 28, "the first date the record reflected service of the final judgment."
Jack Dawson of Miller Dollarhide P.C. in Mustang represented the ranchers. Trevor S. Pemberton of Pemberton Law Group P.L.L.C. in Oklahoma City represented Colyer.
The case returns to the Oklahoma County District Court for further proceedings. The ruling rests on a prima facie showing, an early stage at which uncontroverted allegations are accepted as true and conflicting affidavits are resolved in the plaintiffs' favor. The opinion did not address Colyer's alternative argument that Oklahoma is an inconvenient forum, and it remains subject to revision or withdrawal until released for publication.