CJ-2026-1142 - Hayli L. Hoffman v. Jayvon M. Rose

What's This Case About?

Let’s be real: nobody expects their morning commute to turn into a life-altering disaster while driving past a suburban driveway on a Tuesday afternoon. But for Hayli Hoffman, that’s exactly what happened—when a guy named Jayvon Rose, fresh out of a private driveway at 900 W. Edmond Road like he owns the street, decided the rules of the road were more like suggestions and plowed right into her Jeep. The kicker? The car he was driving wasn’t even his. It belonged to Charles W. Meadows, who apparently thought, “Yeah, sure, let’s let this guy take my Nissan for a spin,” and now both men are being sued for $150,000. Buckle up, folks—this isn’t just a fender bender. This is a full-blown legal rodeo over who’s responsible when someone crashes your car and ruins someone else’s life.

Hayli Hoffman is a regular Oklahoman, living her life in Oklahoma County, just trying to get from point A to point B—specifically, eastbound on W. Edmond Road in Edmond, with three kids safely buckled in the backseat of her shiny 2022 white Jeep Grand Cherokee. No drama, no speed runs, just mom-mode: engaged. On the other side of this story, we’ve got Jayvon M. Rose, the alleged wheelman, and Charles W. Meadows, the guy whose red 2020 Nissan Altima became a projectile. The filing doesn’t tell us how Rose and Meadows know each other—roommates? Cousins? Did Rose borrow the car to pick up tacos and decide to test his luck at Russian roulette with traffic laws? We don’t know. But we do know that on September 13, 2025, Rose was exiting a private driveway—not a public road, not a stoplight, not even a four-way intersection—just a driveway—and decided that Hoffman’s eastbound lane was more of a suggestion than a right-of-way.

According to the petition, Hoffman was in the inside eastbound turn lane, approaching the intersection of S. Kelly Avenue, minding her business, when Rose—attempting to merge onto Edmond Road—just… didn’t stop. Didn’t yield. Didn’t tap the brakes. Didn’t honk. Didn’t signal. Just entered, like he was the main character in a driving video game with infinite lives. The result? A direct hit to the passenger side of Hoffman’s Jeep. Not a glancing blow. Not a scrape. A full-on collision. And while the filing doesn’t say whether airbags deployed or if the kids started screaming, it does say Hoffman suffered “serious personal injuries” that are “permanent, painful, progressive and disfiguring.” She’s racked up medical bills, lost wages, and will continue to endure pain and suffering “in the future.” In other words, this wasn’t a “let’s swap insurance info and go” kind of crash. This was the kind of impact that changes your relationship with driving, with safety, with trust in other humans operating two-ton metal boxes at 30 miles per hour.

Now, here’s where the legal gears start grinding. Hoffman isn’t just suing Jayvon Rose—the guy behind the wheel—for negligence. She’s also suing Charles Meadows—the owner of the car—for something called “negligent entrustment.” And before you roll your eyes and say, “Oh great, another lawsuit where someone blames the car owner,” let’s break this down. In plain English: you can’t just hand your car keys to someone you know is a terrible driver and then say, “Not my problem!” If you give your car to someone reckless, and they hurt someone, you might be on the hook too. That’s what negligent entrustment means. And Hoffman’s legal team is arguing that Meadows knew or should have known that Rose couldn’t drive safely—whether because of inexperience, past behavior, or just bad vibes—but handed over the keys anyway. It’s like lending your kitchen to a pyromaniac and then acting surprised when the house burns down.

The claims are laid out in two causes of action. First, Jayvon Rose was negligent—he was speeding (allegedly), failed to look, failed to use his brakes or turn signal, and violated multiple Oklahoma traffic laws, including sections related to right-of-way, stopping at driveways, and general safe operation. Second, Charles Meadows is being sued for allowing Rose to drive the car in the first place, making him equally liable under the theory that he helped create the danger. Both are accused of “wanton and reckless disregard” for Hoffman’s safety—legal code for “y’all knew better”—which is why she’s asking for punitive damages. And not chump change, either.

Hoffman wants $150,000—split into $75,000 in actual damages (medical bills, lost wages, pain and suffering) and another $75,000 in punitive damages. Now, is $150,000 a lot? In the world of personal injury lawsuits, it’s not exactly small, but it’s not massive either. For context, some car accident cases settle for millions when there are catastrophic injuries or long-term disability. But $150,000 isn’t a slap on the wrist—it’s a serious demand, especially when you consider this isn’t a multi-car pileup on the highway or a drunk driving fatality. This is a driveway-to-Jeep collision. The fact that Hoffman’s team is asking for double the amount in punitive damages as actual damages tells you they’re trying to send a message: “You didn’t just make a mistake. You acted with such disregard for safety that you deserve to pay extra.”

And honestly? The most absurd part isn’t even the crash. It’s the audacity of exiting a private driveway onto a public road without yielding. That’s Driver’s Ed 101. That’s “how not to get your license revoked” 101. That’s “don’t be the guy everyone hates in traffic” 101. And yet, here we are. Jayvon Rose allegedly did the equivalent of stepping off a curb without looking and got hit by a bus—except the bus was a mom in a Jeep, and the “stepping off the curb” was a full-speed merge into active traffic. And Charles Meadows? If he did know Rose was a risky driver, then this whole thing becomes a lesson in accountability: you don’t get to say, “I didn’t drive it,” when you handed the keys to someone who then caused a life-altering crash.

So where do we stand? No jury trial was demanded, which means this might settle out of court—lawyers whispering in hallways, insurance adjusters crunching numbers, maybe a check changes hands, and the case fades into obscurity. But for now, it’s on the record: Hayli Hoffman says her life was changed in an instant by a preventable crash, and she wants both the driver and the car owner to answer for it. We’re not lawyers. We don’t know who’s fully at fault. But we do know this: if you’re going to let someone borrow your car, maybe make sure they know how to drive. And if you’re going to pull out of a driveway, for the love of all things holy, look first. Because someone’s morning commute—and their future—might depend on it.

Case Overview

$150,000 Demand Petition

Jurisdiction

District Court of Oklahoma County, Oklahoma

Filing Attorney

Nicholas G. Farha and Rylee C. Pressgrove

Farha Law, PLLC

Relief Sought

$75,000 Monetary

$75,000 Punitive

Plaintiffs

Hayli L. Hoffman individual
Rep: Nicholas G. Farha, Rylee C. Pressgrove, and Joseph R. ('JR') Homsey, Jr.

Defendants

Jayvon M. Rose individual
Charles W. Meadows individual

Claims

#	Cause of Action	Description
1	Negligence	Plaintiff injured in car accident, alleges defendant driver was negligent and owner liable for entrusting vehicle to defendant
2	Negligence	Plaintiff injured in car accident, alleges defendant owner liable for entrusting vehicle to defendant driver

Petition Text

1,096 words

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA HAYLI L. HOFFMAN, Plaintiff, v. JAYVON M. ROSE and CHARLES W. MEADOWS, Defendant. Case No.: CJ-2026 - 1142 PETITION COMES NOW the plaintiff, Hayli L. Hoffman, by and through her attorneys of record, Nicholas G. Farha and Rylee C. Pressgrove of Farha Law, PLLC, and Joseph R. ("JR") Homsey, Jr. of JR Homsey & Associates, and for her causes of action against the above-named defendants, alleges and states as follows: 1. Plaintiff Hayli L. Hoffman (hereinafter also referred to as "Plaintiff") is a resident of Oklahoma County, State of Oklahoma. 2. Upon information and belief, defendant Jayvon M. Rose (hereinafter also referred to as "Defendant Rose") is a resident of Oklahoma County, State of Oklahoma. 3. Upon information and belief, defendant Charles W. Meadows (hereinafter also referred to as "Defendant Meadows") is a resident of Oklahoma County, State of Oklahoma. 4. At all times mentioned herein, Plaintiff was a restrained driver of a white 2022 Jeep Grand Cherokee SUV automobile. 5. At all times mentioned herein, Defendant Rose was the driver of a red 2020 Nissan Altima automobile. 6. That at the time of the subject accident, Defendant Meadows was the registered owner or co-owner of the red 2020 Nissan Altima automobile, which was negligently entrusted to and driven by Defendant Rose. 7. All acts out of which this cause of action arose were in Oklahoma County, Oklahoma. 8. This Court has jurisdiction, and venue is proper. FIRST CAUSE OF ACTION 9. Plaintiff adopts and re-alleges all material allegations in paragraphs 1 through 8 as if set forth below. 10. The motor vehicle accident that gives rise to this litigation occurred on or about September 13, 2025, at or near the intersection of W. Edmond Road and S. Kelly Avenue, in the City of Edmond, Oklahoma County, State of Oklahoma. 11. That on or about September 13, 2025, Plaintiff Hoffman operated the above-mentioned vehicle while traveling eastbound on W. Edmond Road, with three minor passengers properly retrained inside the vehicle. Defendant Rose operated the above-mentioned vehicle and was attempting to exit the private drive located at 900 W. Edmond Road onto the roadway of W. Edmond Road. As Plaintiff proceeded in the inside eastbound turn lane and approached the intersection of S. Kelly Avenue, Defendant Rose negligently entered the roadway and failed to properly stop and/or yield to the right of way of oncoming traffic and, as a direct result, collided with the passenger side of Plaintiff's vehicle. 12. Defendant Rose had a duty to exercise ordinary care and operate his vehicle in a manner that would not cause injury to Plaintiff or other persons. 13. The accident was caused by the negligence of Defendant Rose in one or more of the following respects: a. He was driving at an unsafe speed; b. He failed to use the vehicle's brakes, horn and/or turning mechanism to avoid the accident; c. He failed to keep a proper lookout for vehicles that were lawfully upon the public roadway; d. He failed to devote full time and attention to operating his vehicle, and e. Negligent per se in that Defendant Rose violated various provisions of Oklahoma’s Motor Vehicle Statutes, including, but not limited to, 47 O.S. §§ 10-103, 11-301, 11-302, 11-305, 11-306, 11-307, 11-309, 11-310, 11-402, 11-704. 14. Defendant Rose’s negligence was the direct and proximate cause of the accident and Plaintiff’s damages. 15. As a direct and proximate result of the negligence of Defendant Rose, Plaintiff suffered serious personal injuries. Said respective injuries are permanent, painful, progressive and disfiguring, 16. As a result of said injuries, Plaintiff has incurred medical bills and expenses for treatment and care and will continue to do so in the future. 17. Plaintiff has suffered permanent physical injuries, mental and physical pain and suffering, loss of enjoyment of life, and she will continue to incur medical bills, lost wages and loss of earning capacity. Further, Plaintiff will continue to endure pain and suffering in the future. 18. The conduct of Defendant Rose was wanton and in reckless disregard of the rights of the Plaintiff, for which Plaintiff is entitled to an award of punitive damages. WHEREFORE, Plaintiff Hayli Hoffman prays the Court enter Judgment in favor of the plaintiff, respectively and against Defendant Rose, jointly and severally with Defendant Meadows on the Plaintiff’s Second Cause of Action, below, on Plaintiffs’ First Cause of Action for actual damages in an amount in excess of $75,000.00, and for punitive damages in an amount in excess of $75,000.00 and/or the amount required for diversity jurisdiction, pursuant to Section 1332 of Title 28 of the United States Code, together with statutory interest, court costs, attorney’s fees, and for such further relief as this Court deems just and proper. SECOND CAUSE OF ACTION 19. Plaintiff adopts and re-alleges all material allegations in paragraphs 1 through 18 as if set forth below. 20. At the time of the accident described herein, the vehicle driven by Defendant Rose was done so with the express permission of Defendant Meadows. 21. The said vehicle was negligently entrusted to Defendant Rose, when Defendant Meadows knew or should have known that Jayvon M. Rose could not operate said vehicle safely, yet allowed said vehicle to be driven by Jayvon M. Rose in disregard for the safety of the Plaintiff. 22. Defendant Meadows was negligent in entrusting said vehicle to Defendant Rose, and as such was a direct and proximate cause of Plaintiff’s injuries. 23. As a direct and proximate result of the negligence of Defendant Meadows, Plaintiff suffered serious personal injuries, as set forth above. 24. The conduct of Defendant Meadows was wanton and in reckless disregard of the rights of Plaintiff, for which Plaintiff is entitled to an award of punitive damages. WHEREFORE, Plaintiff Hayli Hoffman prays the Court enter Judgment in favor of the plaintiff and against Defendant Meadows, jointly and severally with Defendant Rose on the Plaintiff’s First Cause of Action, above, on the Plaintiff’s Second Cause of Action for actual damages in an amount in excess of $75,000.00, and for punitive damages in an amount in excess of $75,000.00 and/or the amount required for diversity jurisdiction, pursuant to Section 1332 of Title 28 of the United States Code, together with statutory interest, court costs, attorney’s fees, and for such further relief as this Court deems just and proper. Respectfully submitted, [Signature] Nicholas G. Farha, OBA No. 21170 Rylee C. Pressgrove, OBA No. 36760 FARHA LAW, PLLC 1900 NW Expressway, Suite 1220 Oklahoma City, Oklahoma 73118 Telephone: (405) 471-2224 Facsimile: (405) 810-9901 Email: [email protected] [email protected] and Joseph R. ("JR") Homsey, Jr. OBA No. 4340 JR Homsey & Associates 4528 N. Classen Blvd. Oklahoma City, Oklahoma 73118 Telephone: 405-524-1011 Facsimile: 405-524-1015 Email: [email protected] ATTORNEY'S LIEN CLAIMED ATTORNEYS FOR THE PLAINTIFF