Barfell v. Freeman Health System: Oklahoma Courts Must Apply Ford’s “Relate To” Prong When Assessing Specific Personal Jurisdiction

I. Introduction

Barfell v. Freeman Health System and Gulshan Uppal, M.D. is a personal-jurisdiction decision arising from a multi-provider medical negligence suit filed by Whitney Barfell, an Oklahoma patient. After treatment in Oklahoma and then in Joplin, Missouri, Barfell sued numerous healthcare providers in Ottawa County District Court (Oklahoma). Two Missouri-based defendants—Freeman Health System (“FHS”) and neurologist Gulshan Uppal, M.D. (“Dr. Uppal”)—moved to dismiss for lack of personal jurisdiction.

The district court dismissed both for want of personal jurisdiction, and the Court of Civil Appeals affirmed. The Oklahoma Supreme Court granted certiorari, vacated the COCA opinion, and held the district court’s analysis was incomplete because it addressed only whether the claims “arise out of” the defendants’ Oklahoma contacts, without analyzing whether the claims “relate to” those contacts as required by Ford Motor Co. v. Mont. 8th Jud. Dist. Ct.

II. Summary of the Opinion

The Supreme Court held that Oklahoma’s long-arm statute, 12 O.S.Supp.2022, § 2004(F), extends jurisdiction to the constitutional limit, so the controlling inquiry is federal due process “minimum contacts” and fairness. Applying modern specific-jurisdiction doctrine (especially Ford Motor Co. v. Mont. 8th Jud. Dist. Ct and the Court’s own Galier v. Murco Wall Products, Inc.), the Court concluded:

• As to FHS: Barfell produced evidence of substantial Oklahoma-directed contacts (registration to do business, leased buildings and operations in Grove and Miami, staffing/clinics including at Quapaw, Oklahoma advertising, billboards, and substantial Oklahoma patient volume). Because the district court failed to analyze whether the claims “relate to” those contacts, dismissal was reversed and the case remanded for further proceedings, including consideration of jurisdictional discovery and the “relate to” prong.
• As to Dr. Uppal: On this record, Barfell failed to meet her burden to show purposeful availment (undisputedly he did not live, own property, practice, or see patients in Oklahoma). The Court affirmed dismissal (without prejudice) on an alternative basis even though the district court’s reasoning was incomplete.

Procedurally, the Court vacated the COCA opinion, affirmed in part and reversed in part the district court judgment, and remanded.

III. Analysis

A. Precedents Cited (and How They Shaped the Decision)

1. Burden framework and standard of review

• Guffey v. Ostonakulov (abrogated on other grounds): Supplies the burden-shifting structure—defendant must first raise jurisdictional facts (typically by motion/affidavits), then plaintiff must prove jurisdictional facts. The Court used this to frame why Barfell’s evidentiary showing mattered, and why her showing differed as to FHS versus Dr. Uppal.
• Montgomery v. Airbus Helicopters, Inc.: Confirms personal jurisdiction is reviewed de novo and the appellate court “search[es] the record” for minimum contacts consistent with “traditional notions of fair play and substantial justice.”
• Bristol-Myers Squibb Co. v. Super. Ct. of Cal., S.F. Cty.: Appears in two roles—(i) as the basis for the “abrogated on other grounds” note in the Guffey line, and (ii) substantively, as a contrast case (no jurisdiction where forum contacts lacked a meaningful link to the plaintiffs’ claims).

2. Oklahoma’s long-arm statute and constitutional minimum contacts

• Galier v. Murco Wall Products, Inc. and State ex rel. Edmondson v. Native Wholesale Supply: Used to reaffirm that Oklahoma’s long-arm statute (§ 2004(F)) is coextensive with state and federal constitutional limits—making the due process analysis decisive.
• Int 1 Shoe Co. v. Washington (and also referenced as International Shoe): The foundational “minimum contacts” and “fair play and substantial justice” framework. The Court treated these as the baseline constraints informing all subsequent specific-jurisdiction doctrine.

3. Specific jurisdiction’s modern “arise out of or relate to” test

• Ford Motor Co. v. Mont. 8th Jud. Dist. Ct: The controlling authority for the central error identified. The Court emphasized that “arise out of” often connotes causation, but “relate to” permits jurisdiction without a strict causal showing when the relationship among defendant, forum, and litigation is sufficiently close—particularly where the defendant “systematically served” the forum market.
• Burger King Corp. v. Rudzewicz, Hanson v. Denckla, Keeton v. Hustler Magazine, Inc., and Walden v. Fiore: Quoted via Ford to define “purposeful availment” and exclude “random, isolated, or fortuitous” contacts, underscoring that the defendant’s own choices must create the forum link.
• Helicopteros Nacionales de Colombia, S. A. v. Hall and Goodyear: Cited in the Ford quotation chain to distinguish jurisdiction types and illustrate the requirement of an “affiliation between the forum and the underlying controversy.”
• World-Wide Volkswagen Corp. v. Woodson: Used to reinforce the “systematic contacts” idea and to ground the “gestalt factors” (fairness/sovereignty) lens later emphasized in Galier.

4. Oklahoma authority on inferring purposeful availment

• Crescent Corp. v. Martin: Quoted (through Galier) for the proposition that purposeful availment “may be shown by circumstances from which such fact may be reasonably inferred.” This matters because FHS’s Oklahoma footprint is largely proven circumstantially (operations/marketing/patient volume), not via a single causative act.

5. Older physician-contact case distinguished

• Vance v. Molina: The district court attached it as an exhibit. The Supreme Court noted Vance found no jurisdiction over a Texas doctor where the only Oklahoma contacts were Oklahoma-initiated follow-up calls. The Court explained why Vance does not carry the day here: Barfell alleged substantially more contacts for FHS, and Vance predates Ford’s clarified distinction between “arise from” and “relate to.”

6. “Right result, wrong reason” and partial affirmance/reversal

• Nichols v. Nichols (and the supporting string cited therein): Akin v. Mo. Pac. Ry’ Co., Bivins v. State ex rel. Okla. Mem. Hosp., Suagee v. Cook (In re Estate of Maheras), Wright v. Grove Sun Newspaper Co., Willis v. Nowata Land & Cattle Co., Davidson v. Gregory, Utica Nat’l Bank & Tr. Co. v. Associated Producers Co., and (0.4. Mosites Co. of It. Worth, Inc. v . Aetna Cas. & Cur. Co.: These authorities support affirming a correct outcome even if the lower court’s reasoning was flawed. The Court used this doctrine to affirm dismissal of Dr. Uppal (because Barfell failed to meet her burden on purposeful availment), while reversing as to FHS (where an alternative basis for affirmance was not apparent on the record).

B. Legal Reasoning

1. The doctrinal “gap” the Court identified

The district court’s jurisdictional analysis stopped after concluding Barfell’s claims did not “arise out of” (i.e., were not caused by) the defendants’ Oklahoma contacts because treatment occurred in Missouri. The Supreme Court held that approach is incomplete after Ford Motor Co. v. Mont. 8th Jud. Dist. Ct: even absent a causal nexus, a court must analyze whether the claim “relates to” the defendant’s forum contacts.

2. Application to FHS: substantial forum-directed contacts, but “relate to” not assessed

The Court cataloged Barfell’s evidentiary proffer showing Oklahoma-directed contacts by FHS: being registered to do business in Oklahoma; leasing buildings and operating medical facilities in Grove and Miami; operating/staffing a clinic in a casino in Quapaw; employing Oklahoma residents at Oklahoma facilities; advertising Oklahoma facilities and a regional service area including Oklahoma; placing billboards in Oklahoma; advertising on Missouri television reaching northeast Oklahoma; and serving thousands of Oklahoma-address patients in Joplin.

That showing was sufficient—at least “at this juncture”—to prevent dismissal without the trial court performing the missing analysis (and potentially allowing additional jurisdictional discovery). Importantly, the Court did not hold Oklahoma definitively has specific jurisdiction over FHS; it held the district court erred by not completing the required Ford inquiry and fairness analysis.

3. Application to Dr. Uppal: no purposeful availment shown on this record

In contrast, the Court treated Dr. Uppal’s case as evidentiary failure under the burden framework of Guffey v. Ostonakulov. The undisputed facts were that he did not live in Oklahoma, own property in Oklahoma, practice medicine in Oklahoma, or see any patients in Oklahoma. Barfell’s allegation that a website listed him as “admitted” at an Oklahoma hospital was unsupported by a legible exhibit and was deemed insufficient to show he “purposefully avail[ed] himself of conducting activities within Oklahoma.”

Thus, even though the district court’s reasoning was incomplete under Ford, the result (dismissal of Dr. Uppal) could be affirmed under Nichols v. Nichols as a right result supported by an alternative basis.

4. Fairness (“gestalt factors”) remains part of the analysis

Echoing Galier v. Murco Wall Products, Inc. and World-Wide Volkswagen Corp. v. Woodson, the Court reiterated that even when minimum contacts are shown, courts must assess “reasonableness” factors: burden on the defendant; forum state interest; plaintiff’s interest in convenient and effective relief; efficiency; and shared interstate policy interests. The remand signals that these factors should be evaluated once the “relate to” prong is properly addressed.

C. Impact

1. Practical directive to trial courts

The opinion functions as a procedural correction: Oklahoma trial courts deciding motions to dismiss for lack of specific personal jurisdiction must explicitly analyze both halves of the Ford formulation—whether claims “arise out of” or relate to the defendant’s forum contacts—rather than treating “arise out of” (causation) as the sole gatekeeper.

2. Consequences for multi-state healthcare systems

For integrated healthcare systems that operate facilities, advertise, and cultivate patient markets across state lines, Barfell increases the likelihood that jurisdictional dismissals will be premature if courts do not consider whether litigation “relates to” those market-serving activities. The decision invites more robust jurisdictional discovery where a plaintiff presents a non-frivolous showing of substantial forum-directed operations and marketing.

3. Continued protection for individual physicians without forum-directed conduct

At the same time, the Court’s affirmance as to Dr. Uppal underscores a limiting principle consistent with Walden v. Fiore: specific jurisdiction cannot be manufactured from the plaintiff’s forum connections or from unsupported allegations. Purposeful availment must be shown with competent proof, and the burden remains on the plaintiff once jurisdiction is challenged.

4. Litigation strategy effects

• Plaintiffs will likely plead and prove broader “systematically served market” facts (operations, advertising reach, patient sourcing, employment footprint) to satisfy the “relate to” prong.
• Defendants will likely focus on narrowing the connection between forum-market activity and the particular care episode, while pressing fairness factors and contesting evidentiary sufficiency (especially for individuals).
• Trial courts may more frequently allow limited jurisdictional discovery when the plaintiff’s proffer suggests non-trivial forum-directed activity.

IV. Complex Concepts Simplified

• Personal jurisdiction: A court’s power to require a defendant to defend a lawsuit in that state.
• General vs. specific jurisdiction: General (“all-purpose”) lets you sue a defendant in the forum for almost anything, typically where the defendant is “at home.” Specific (“case-linked”) permits suit only when the case is sufficiently connected to the defendant’s forum contacts.
• Purposeful availment: The defendant must have deliberately created contacts with the forum (not accidental or purely because the plaintiff lives there).
• “Arise out of” vs. “relate to”: “Arise out of” often implies causation (the forum contact caused the injury). “Relate to” is broader after Ford Motor Co. v. Mont. 8th Jud. Dist. Ct: jurisdiction may exist even without strict causation if the defendant systematically served the forum market and the controversy is sufficiently connected to that forum-directed activity.
• Jurisdictional discovery: Limited evidence-gathering (documents/depositions) focused on whether the defendant’s contacts with the forum are enough for jurisdiction.
• “Gestalt factors” / fairness factors: Even with contacts, courts consider whether asserting jurisdiction is reasonable (burdens, state interests, efficiency, and interstate policy).
• “Right result, wrong reason”: Under Nichols v. Nichols, an appellate court may affirm if the outcome is correct on another legal basis, even if the trial court’s reasoning was flawed.

V. Conclusion

Barfell cements an operational rule for Oklahoma courts applying specific personal jurisdiction: the inquiry does not end when a claim fails a strict “arise out of” (causation) test. After Ford Motor Co. v. Mont. 8th Jud. Dist. Ct—and consistent with Oklahoma’s own Galier v. Murco Wall Products, Inc.—trial courts must also decide whether the claim “relates to” the defendant’s forum-directed activities and then evaluate fairness factors.

The decision simultaneously (1) opens the door to jurisdictional development against a multi-state healthcare system with substantial Oklahoma operations/marketing (FHS), while (2) preserving the due process boundary for an out-of-state physician where the plaintiff fails to prove purposeful availment (Dr. Uppal). In broader context, the opinion aligns Oklahoma practice with modern U.S. Supreme Court doctrine, emphasizing relationship-based specific jurisdiction over rigid causation alone.