Okla. Stat. » Title 12 — CIVIL PROCEDURE
Oklahoma Statutes

Okla. Stat. tit. 12, § 2018 (2026)

Joinder of claims and remedies

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JOINDER OF CLAIMS AND REMEDIES A. JOINDER OF CLAIMS. A party asserting a claim to relief as an original claim, counterclaim, cross-claim, or third-party claim, may join, either as independent or as alternate claims, as many claims, legal or equitable, as he has against an opposing party. B. JOINDER OF REMEDIES; FRAUDULENT CONVEYANCES. Whenever a claim is one heretofore cognizable only after another claim has been

prosecuted to a conclusion, the two claims may be joined in a single action; but the court shall grant relief in that action only in accordance with the relative substantive rights of the parties. In particular, a plaintiff may state a claim for money and a claim to have set aside a conveyance fraudulent as to him, without first having obtained a judgment establishing the claim for money. C. CONSOLIDATION. When actions involving a common question of law or fact are pending before the court, it may order a joint hearing or trial of any or all the matters in issue in the actions; it may order all the actions consolidated; and it may make such orders concerning proceedings therein as may tend to avoid unnecessary costs or delay. D. SEPARATE TRIALS. The court, in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial of any claim, cross-claim, counterclaim, or third-party claim, or of any separate issue or of any number of claims, cross-claims, counterclaims, third-party claims, or issues, always preserving inviolate the right of trial by jury. Added by Laws 1984, c. 164, § 18, eff. Nov. 1, 1984.

Notes of Decisions
Cited in 16 cases (2 in the last 5 years), 1987–2024 · leading case: Buzzard v. McDanel, 736 P.2d 157 (Okla. 1987).
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Buzzard v. McDanel, 736 P.2d 157 (Okla. 1987). · cites it 12× “At issue presently is an order of the trial court in that case granting Farmers' motion pursuant to 12 O.S.Supp. 1984 § 2018(D) to require petitioners to first litigate, as a separate issue, whether petitioners were legally entitled to recover from the City of Norman before the…”
A-Plus Janitorial & Carpet Cleaning v. Employers' Workers' Comp. Ass'n, 1997 OK 37, 936 P.2d 916. · cites it 8× “Whenever a claim is one heretofore cognizable only after another claim has been prosecuted to a conclusion, the two claims may be joined in a single action; but the court shall grant relief in that action only in accordance with the relative substantive rights of the parties.”
Ward Petroleum Corp. v. Stewart, 2003 OK 11, 64 P.3d 1113. · cites it 2× “A trial judge is authorized to conduct separate trials of any number of claims in a lawsuit by 12 O.S.2001, § 2018(D) of the Oklahoma Pleading Code.”
Graham v. Keuchel, 847 P.2d 342 (Okla. 1993). · cites it 2× “[72] See 12 O.S.Supp. 1984 § 2018, which governs bifurcation; it provides in pertinent part: "D.”
Thomas v. E-Z Mart Stores, Inc., 2004 OK 82, 102 P.3d 133. · cites it 2× “12 O.S.2001 § 2018(C). [5] We have indicated that a jury may be confused when it simultaneously addresses different claims involving the same defendants and one claim requires a determination of negligence and other does not.”
State v. One Thousand Two Hundred Sixty-Seven Dollars, 2006 OK 15, 131 P.3d 116. · cites it 2× “19 The terms of 12 O.S.2001 § 2018(C) 20 provide for consolidation of pending actions that deal with common questions of law or fact.”
Cary v. Oneok, Inc., 1997 OK 60, 940 P.2d 201. · cites it 2× “[5] The terms of 12 O.S.1991 § 2018 provide in pertinent part: "* * * D.”
Nicholas v. Morgan, 2002 OK 88, 58 P.3d 775. “12 O.S.2001, § 2018. 5 . Although the language in the most recent codification of § 44 remains the same as the 1991 version, this opinion references the 1991 statute.”
Landrum v. Nat'l Union Ins. Co., 912 P.2d 324 (Okla. 1996). · cites it 2× “1984 § 2024, the Civil Procedure Committee of the Oklahoma Bar Association said, “The court can take any appropriate steps to prevent the intervenor from prejudicing the trial of the action.”
Oklahoma Gas & Elec. Co. v. Dist. Court, 784 P.2d 61 (Okla. 1989). “12 O.S.Supp.1984 § 2018(C) provides for the consolidation of "actions involving a common question of law or fact,” and authorizes the issuance of orders "concerning proceedings therein as maj' tend to avoid unnecessary costs or delay.”
Rose Grp., L.L.C. v. Miller, 2003 OK CIV APP 18, 64 P.3d 573. “In response, As-signee argued (1) the original tort claim, once it was reduced to judgment, was assignable, (2) its claims are assignable because they survive the victim and arise out of contract between Miller and the insiders and affiliates, (3) the purpose of requiring that…”
Knight v. McBee, 767 P.2d 878 (Okla. 1988). “Because a legal cause of action cannot be split or divided, it is not subject to bifurcation for trial purposes within the meaning of 12 O.S.Supp.1984 § 2018(D) in the absence of some compelling circumstances.”
Show all 16 citing cases →
Okla. Stat. tit. 12, § 2018(A): 1 case
A-Plus Janitorial & Carpet Cleaning v. Employers' Workers' Comp. Ass'n, 1997 OK 37, 936 P.2d 916. “Whenever a claim is one heretofore cognizable only after another claim has been prosecuted to a conclusion, the two claims may be joined in a single action; but the court shall grant relief in that action only in accordance with the relative substantive rights of the parties.”
Okla. Stat. tit. 12, § 2018(B): 1 case
Rose Grp., L.L.C. v. Miller, 2003 OK CIV APP 18, 64 P.3d 573. “In response, As-signee argued (1) the original tort claim, once it was reduced to judgment, was assignable, (2) its claims are assignable because they survive the victim and arise out of contract between Miller and the insiders and affiliates, (3) the purpose of requiring that…”
Okla. Stat. tit. 12, § 2018(C): 6 cases
Thomas v. E-Z Mart Stores, Inc., 2004 OK 82, 102 P.3d 133. “12 O.S.2001 § 2018(C). [5] We have indicated that a jury may be confused when it simultaneously addresses different claims involving the same defendants and one claim requires a determination of negligence and other does not.”
A-Plus Janitorial & Carpet Cleaning v. Employers' Workers' Comp. Ass'n, 1997 OK 37, 936 P.2d 916. “Whenever a claim is one heretofore cognizable only after another claim has been prosecuted to a conclusion, the two claims may be joined in a single action; but the court shall grant relief in that action only in accordance with the relative substantive rights of the parties.”
State v. One Thousand Two Hundred Sixty-Seven Dollars, 2006 OK 15, 131 P.3d 116. “19 The terms of 12 O.S.2001 § 2018(C) 20 provide for consolidation of pending actions that deal with common questions of law or fact.”
Oklahoma Gas & Elec. Co. v. Dist. Court, 784 P.2d 61 (Okla. 1989). “12 O.S.Supp.1984 § 2018(C) provides for the consolidation of "actions involving a common question of law or fact,” and authorizes the issuance of orders "concerning proceedings therein as maj' tend to avoid unnecessary costs or delay.”
Kent v. City of Oklahoma City, 2020 OK CIV APP 21.
Okla. Stat. tit. 12, § 2018(D): 4 cases
Buzzard v. McDanel, 736 P.2d 157 (Okla. 1987). “At issue presently is an order of the trial court in that case granting Farmers' motion pursuant to 12 O.S.Supp. 1984 § 2018(D) to require petitioners to first litigate, as a separate issue, whether petitioners were legally entitled to recover from the City of Norman before the…”
Ward Petroleum Corp. v. Stewart, 2003 OK 11, 64 P.3d 1113. “A trial judge is authorized to conduct separate trials of any number of claims in a lawsuit by 12 O.S.2001, § 2018(D) of the Oklahoma Pleading Code.”
Knight v. McBee, 767 P.2d 878 (Okla. 1988). “Because a legal cause of action cannot be split or divided, it is not subject to bifurcation for trial purposes within the meaning of 12 O.S.Supp.1984 § 2018(D) in the absence of some compelling circumstances.”
Covington Specialty Ins. Co. v. G & G Farms, Inc., No. 6:22-cv-00227 (E.D. Okla. Mar. 4, 2024).
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