THE OKLAHOMA BAR JOURNAL 20 | FEBRUARY 2026 Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff. 2024, SOK mailed him a notice and order of revocation that was dated June 23, 2023.35 Despite not sending the notice for over six months from the date it was created, SOK did, in fact, revoke Mr. White’s driving privileges on the original date of the notice without giving him meaningful notice.36 The appellate court determined the actions by SOK did not provide Mr. White with notice, and, thus, those actions were taken without a reasonable basis or were frivolous.37 Consequently, SOK was held liable for Mr. White’s reasonable attorney fees and costs. CONCLUSION The administrative side of a DUI or APC is an ever-changing landscape through legislative changes and procedural challenges. It is a highly nuanced area of law that requires thorough research and commitment to stay current on the changes and their applications. ABOUT THE AUTHOR Sabah Khalaf is the owner and managing attorney of the Khalaf Law Firm in Tulsa. His practice is focused on high-stakes litigation and criminal matters. Mr. Khalaf practices in federal, state, tribal and municipal criminal courts from prefiling investigations to trial. ENDNOTES 1. Hunsucker v. Fallin, 2017 OK 100, ¶¶14-15; see also Bell v. Burson, 402 U.S. 535, 542 (1971). 2. 47 O.S. §751 (A). 3. 47 O.S. §754 (B). 4. 47 O.S. §754 (C). 5. 47 O.S. §754; Smith v. State ex rel. Dept. of Pub. Safety, 680 P.2d 365, 368, 1984 OK 16, ¶6 (Okla. 1984). 6. 47 O.S. §759. 7. 47 O.S. §6-212.5. 8. Id. 9. Id. 10. Hollis v. State, ex rel. Dept. of Public Safety, 2008 OK 31, ¶8, 183 P.3d 996, 999. 11. 47 O.S. §6-211(A). 12. Muratore v. State ex rel. Dep’t of Pub. Safety, 2014 OK 3, 320 P.3d 1024 (2014). 13. 47 O.S. §754. 14. 47 O.S. §6-205. 15. 47 O.S. §6-211. 16. 47 O.S. §6-212.5. 17. 47 O.S. §6-211(H). 18. 47 O.S. §6-205.1(A)(1). 19. Id. 20. Id. 21. 12 O.S. §941. 22. Johnson v. State, ex. rel. DPS, 2018 OK CIV APP 4, ¶2. 23. Id. at ¶3. 24. Johnson v. State, ex. rel. DPS, 2018 OK CIV APP 4. 25. Miller v. State ex. rel. DPS, 1996 OK CIV APP 71. 26. Id. 27. Id. 28. Currington v. State ex. rel., DPS. 2022 OK Civ. App. 1. 29. Id. 30. Id. 31. Id. 32. White v. State, ex. rel. Serv. Okla., 2025 OK CIV APP 20, at ¶¶1 and 14. 33. Id. at ¶2. 34. Id. 35. Id. at ¶4. 36. Id. 37. Id. at ¶11.
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