1. Introduction

This decision addresses a question of first impression under the Oklahoma Open Records Act (ORA), 51 O.S.2022, §§ 24A.1 et seq.: whether a county detention center operated by a public trust formed under 60 O.S.2022, § 176 et seq. and 19 O.S.2022, §§ 904.2—904.10 qualifies as a “law enforcement agency” under 51 O.S.2022, § 24A.3(5).

Plaintiff/Appellant James Lawson, a bail bondsman, requested records (including audio/video footage, policies and procedures, and employee names) from the LeFlore County Detention Center Public Trust (the Jail Trust). The Jail Trust denied key portions of the request by invoking ORA provisions applicable to “law enforcement agencies,” particularly the discretionary and exempt treatment of certain “law enforcement records” under 51 O.S.2022, § 24A.8. The district court accepted that characterization and granted summary judgment to the Jail Trust. The Oklahoma Supreme Court reversed, holding the statutory definition is unambiguous and the Jail Trust does not fit it.

Key legal issue: Whether the Jail Trust is “any public body charged with enforcing state or local criminal laws and initiating criminal prosecutions” within the meaning of 51 O.S.2022, § 24A.3(5).

2. Summary of the Opinion

The Court held that the ORA’s definition of “law enforcement agency” in 51 O.S.2022, § 24A.3(5) is plain and unambiguous and imposes an exhaustive, conjunctive definition: the entity must be a “public body” and be charged with (i) enforcing state or local criminal laws and (ii) initiating criminal prosecutions.

Although the Jail Trust is a “public body,” it is not charged with enforcing criminal laws and it does not initiate criminal prosecutions (indeed, it admitted it does not). Operating a jail and performing statutory duties analogous to a sheriff’s jail-management responsibilities does not transform the public trust into a law enforcement agency—especially where statutes make clear that conferring the sheriff’s operational duties on a trust does not confer peace-officer status.

Disposition: summary judgment reversed; case remanded for further proceedings consistent with the opinion. Because the Jail Trust was not a “law enforcement agency,” the Court did not reach the “public interest outweighs denial” balancing issue that would arise under 51 O.S.2022, § 24A.8(B).

3. Analysis

3.1 Precedents Cited (and Their Role)

• Carmichael v. Beller (1996 OK 48): Cited for the summary-judgment framework—trial courts decide whether genuine issues of material fact exist and whether a party is entitled to judgment as a matter of law; the ultimate question is legal. The Court used this to justify its independent review of the dispositive legal question (statutory meaning).
• Citizens Against Taxpayer Abuse, Inc. v. City of Oklahoma City (2003 OK 65): Used twice: (1) for de novo review and the nature of plenary appellate authority; and (2) for a core ORA principle—records must be disclosed unless an exemption applies, and the public body bears the burden to establish the exemption. This baseline pro-disclosure policy underlies the Court’s reluctance to expand exemptions beyond statutory text.
• Fulsom v. Fulsom (2003 OK 96): Cited for the proposition that statutory interpretation is reviewed de novo on appeal, reinforcing that the “law enforcement agency” question is primarily interpretive rather than factual.
• Okla. Pub. Emps. Ass’n v. State ex rel. Okla. Office of Personnel Mgmt. (2011 OK 68): Invoked to articulate the ORA’s democratic purpose—government openness as a check on secrecy and abuse of power—supporting a reading that favors access unless the statute clearly restricts it.
• Okla. Ass’n of Broad., Inc. v. City of Norman (2016 OK 119): Cited for the interpretive thumb on the scale: ORA provisions should be construed to allow access unless an exception clearly applies, with the burden on the agency denying access.
• McClure v. ConocoPhillips Co (2006 OK 42) and World Pub. Co. v. White (2001 OK 48): Both support a disciplined approach to statutory definitions. Where the Legislature supplies a definition, courts must apply it, presuming it reflects legislative intent.
• Neer v. State ex rel. Okla. Tax Comm’n (1999 OK 41): Used to reinforce that, absent contrary legislative indication, statutory terms receive their plain and ordinary meaning.
• Ford v. Okla. Tax Comm’n (1955 OK 168) and Ford v. Oklahoma Tax Comm’n (same case name appears later with “Oklahoma” spelled out): Cited for the rule that statutes are not open to judicial construction “as a matter of course,” emphasizing restraint.
• Am. Airlines, Inc. v. State ex rel. Okla. Tax Comm’n (2014 OK 95): Quoted for the “cardinal rule” that legislative intent is found in the statutory language—again steering the decision toward text rather than functional analogies (e.g., “steps into the sheriff’s shoes”).
• Sanders v. Turn Key Health Clinics (2025 OK 19): A contemporary articulation of textualism: when the Legislature speaks clearly, courts apply the text without resort to interpretive canons.
• In re J.L.M. (2005 OK 15): Cited for the definition of ambiguity—only ambiguous if susceptible to more than one reasonable interpretation—supporting the Court’s conclusion that § 24A.3(5) is unambiguous.
• Yocum v. Greenbriar Nursing Home (2005 OK 27): Reinforces the threshold: only if intent cannot be ascertained from text (ambiguity or conflict) may rules of construction be employed.
• Question Submitted by Hon. Charlie Laster, State Sen., Dist. No. 18 (2004 OK AG 17): Used not as binding precedent but as persuasive context: a jail trust “functions as county jailer,” akin to the common-law jailer. The Court leveraged this to distinguish “custodial” duties from “law enforcement” and “prosecution-initiating” functions.
• Webber v. State (1925 OK 736): Cited for a constitutional criminal-procedure principle: prosecutions in courts of record commence by indictment or information (Okla. Const. art. II, § 17). The Court used this to frame what it means to “initiate” prosecutions and why entities beyond prosecutors can still “initiate” in a broader sense (through investigatory charge proposals).
• Toxic Waste Impact Group, Inc. v. Leavitt (1988 OK 20): Quoted for a separation-of-powers caution: courts may not “expand the plain wording of a statute by construction.” This directly supports the Court’s refusal to add “jail trusts” to § 24A.3(5) by implication.

3.2 Legal Reasoning

The Court’s reasoning is a strict application of the ORA’s definitional text.

(a) The definition is conjunctive and exhaustive.

Grammatically, “charged with” governs both verbs—“enforcing” and “initiating”—because the statute uses the conjunction “and” without introducing a new controlling verb. This matters: an entity that only performs custody/operations but neither enforces criminal laws nor initiates prosecutions cannot qualify.

(b) “Public body” was satisfied, but that was not enough.

The Jail Trust was a “public body” under § 24A.3(2), which expressly includes a “trust,” and it was funded by the county. The Court accepted this element as undisputed.

(c) The Jail Trust is not “charged with enforcing state or local criminal laws.”

The Court drew a sharp line between (i) custodial administration of confinement and (ii) enforcing criminal laws (e.g., policing powers, statewide enforcement authority, arrest powers associated with peace officers). While statutes assign jail-operation duties to trusts (and treat sheriff/jailer duties as the trust’s for management and services), the Court emphasized that the same statutory scheme expressly does not confer “peace-officer status” on the trust. This statutory “no peace-officer status” signal undermined any functional-equivalence argument.

The Court also compared the ORA’s enumerated examples—police departments, county sheriffs, DPS, OBNDDC, ABLE, OSBI—entities associated with enforcement authority. The Jail Trust’s role as “jailer” (housing and guarding those confined by lawful warrant) is materially different.

(d) The Jail Trust does not “initiat[e] criminal prosecutions.”

The Court defined “initiating” broadly enough to include early-stage functions typical of police and sheriffs, not just prosecutors: investigations, evidence gathering, and “propos[ing]” charges that form the basis for an information or indictment. The Court supported this breadth by (i) criminal procedure statutes describing how charges proceed and are verified and (ii) examples of other Oklahoma statutes that use “initiate/instigate/institute/cause” prosecution language for agencies and boards.

Even under this broad understanding, the Jail Trust failed the element—critically, because it admitted it does not initiate criminal prosecutions, and the record lacked evidence that it proposes charges or performs comparable initiating functions.

(e) “Steps into the shoes” arguments cannot override text.

The district court had accepted, at least in part, the idea that the trust “steps into the shoes” of the sheriff for operating the jail and thus should be treated like a sheriff for ORA purposes. The Supreme Court rejected that move as an impermissible expansion of the statute: if the Legislature wanted jail trusts included, it could have said so plainly.

3.3 Impact

• Immediate ORA consequence: County jail public trusts cannot rely on the ORA’s law-enforcement-specific disclosure regime in 51 O.S.2022, § 24A.8 merely because they operate a jail. Their records requests are evaluated under the general ORA provisions applicable to public bodies (e.g., 51 O.S.2022, § 24A.5), subject to whatever other specific exemptions may apply.
• Narrowing of discretionary withholding: § 24A.8(B) provides discretionary non-disclosure for law enforcement agencies (subject to a balancing test in some circumstances). By holding jail trusts are not “law enforcement agencies,” the Court removes a major discretionary shield from these entities and increases the likelihood of mandatory disclosure unless another exemption applies.
• Textual boundary for “functional equivalence” claims: The opinion signals that statutory assignment of operational duties (even “sheriff-like” duties) does not automatically carry definitional consequences under the ORA. Future litigants will likely need to prove the specific definitional elements—particularly enforcement authority and prosecution-initiating functions—rather than relying on analogy.
• Legislative invitation: The Court explicitly noted that if the Legislature intends jail trusts to receive law-enforcement-agency treatment under the ORA, it can amend § 24A.3(5) to say so. That statement may catalyze legislative activity, especially from counties or trusts concerned about security-sensitive records.
• Case-by-case downstream litigation: While the Court resolved only the definitional question, the remand means the parties (and future requesters) may litigate which specific jail records are disclosable under other ORA provisions and exemptions. The decision re-centers those fights on the ORA’s general disclosure rules rather than § 24A.8’s law enforcement framework.

4. Complex Concepts Simplified

• Summary judgment / de novo review: Summary judgment is granted when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law. “De novo” review means the Supreme Court re-decides the legal question independently, without deferring to the trial court’s interpretation.
• ORA structure (general rule + exemptions): The ORA starts with a broad right of access. Records must be disclosed unless a statute provides an exemption. The government bears the burden of showing the exemption applies.
• Why the definition matters: If an entity is a “law enforcement agency,” § 24A.8 governs many of its records and can make disclosure discretionary. If it is not, the entity generally faces the ORA’s broader disclosure mandate applicable to “public bodies.”
• “Means” vs. “including, but not limited to”: “Means” signals the definition’s requirements must be met. “Including, but not limited to” introduces examples but does not enlarge the definition to cover entities that fail the stated requirements.
• “Enforcing” criminal laws vs. “operating” a jail: “Enforcing” implies authority and duty to compel compliance with criminal laws (often tied to peace-officer powers like arrest). Operating a jail is primarily custodial—holding and managing individuals already committed by lawful process.
• “Initiating” prosecutions (broadly understood): Even though prosecutors file informations/indictments, police and sheriffs can “initiate” prosecutions in a practical sense by investigating, collecting evidence, and presenting charge proposals that become the factual basis for formal filings. The Jail Trust did not perform (and admitted it does not perform) that initiating role.

5. Conclusion

LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM. establishes a clear ORA rule: a county detention center public trust is not a “law enforcement agency” under 51 O.S.2022, § 24A.3(5) unless it is charged with both enforcing criminal laws and initiating criminal prosecutions. Assigning a trust the sheriff’s jail-operation duties does not satisfy those elements and cannot justify importing § 24A.8’s law-enforcement disclosure limitations by analogy.

The decision reinforces Oklahoma’s strong pro-transparency default, confines ORA exemptions to their textual boundaries, and shifts jail-trust record disputes back into the ORA’s general public-body framework unless and until the Legislature amends the statutory definition.