Opinion:Frazier v. Bruce, 2021 OK 14
Subject matter:Rule 15 (disqualification); Sanctions
Date Decided:3/29/2021
Trial Court:Tulsa County
Route to this Court:Application to Assume Original Jurisdiction pursuant to Rule 15
Facts:Mother’s request to disqualify lower court judge was denied by the Supreme Court on January 25, 2021; Father then filed an Application for Attorney’s Fees, alleging Mother’s request to disqualify was frivolous and seeking attorney’s fees as sanction. 
Standard of Review:Okla. Sup. Ct. R. 1.191(J) (sanctions in original proceedings)
Analysis:The Court noted that the law has long been settled that an adverse ruling by  the trial court is insufficient to seek recusal of the judge; the Court concluded that Mother’s Rule 15 proceedings amounted to a frivolous filing and was used only to delay and disrupt lower court proceedings; the Court granted Father’s request for attorney’s fees as a sanction against Mother. 
Outcome:Motion for Attorney’s Fees granted; trial court ordered to hold a hearing to determine amount of fees. 
Vote:Darby, C.J., Kane, V.C.J., Winchester, Edmondson, Combs, JJ., concur; Gurich, J., concur in result; Kauger, Rowe, JJ., dissent. 
Other: Done by Order of the Court; not written by any particular Justice.