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MCCLAIN COUNTY • CJ-2026-00065

Kaleb Reno v. Jimmy Rowley

Filed: Mar 3, 2026
Type: CJ

What's This Case About?

Let’s be real: how many times have you been minding your own business on a motorcycle, legally passing some slow-moving traffic, only to have a Cintas van suddenly lurch into the oncoming lane like it’s auditioning for a Fast & Furious spin-off about uniform delivery gone wrong? If your answer is “never,” congrats — you’re not Kaleb Reno. Because on June 27, 2024, in the quiet Oklahoma city of Newcastle, that’s exactly what happened. One moment, Kaleb was cruising north on N. Portland Avenue, the next — boom — he was airborne, unconscious, and about to become the plaintiff in what might be the most dramatic workplace liability case involving a blue-and-white service van since… well, ever.

So who are these people? On one side, we’ve got Kaleb Reno — motorcyclist, presumably a fan of wind in his hair and not in his emergency room chart. He’s an Oklahoma local, just trying to get from point A to point B on his bike like any reasonable human. On the other side? Jimmy Rowley, employee of Cintas Corporation No. 2 — yes, that Cintas, the company that brings you clean uniforms, fire extinguishers, and apparently, occasionally, catastrophic traffic hazards. Rowley was behind the wheel of a big commercial van, doing whatever Cintas guys do — maybe delivering aprons to a diner or checking smoke detectors at a laundromat. We don’t know. What we do know is that he was driving a vehicle owned by a multi-billion-dollar corporation with operations in every state, and he was allegedly doing it like he’d never seen a turn signal before.

Now, let’s set the scene. It’s a regular day. Reno’s riding his motorcycle northbound on a single-lane road — nothing fancy, just doing the legal thing. Ahead of him, there’s a dumpster truck puttering along. No big deal. Reno sees an opening, checks for oncoming traffic (there isn’t any), and begins passing the dumpster truck on the left. Standard motorcycle maneuver. Smooth. Lawful. Reasonable. But then — plot twist — Jimmy Rowley, who’s driving a Cintas van in front of the dumpster truck, decides, for reasons known only to him and possibly his GPS, that it’s time to make a left turn into a private driveway. Except he doesn’t signal. Doesn’t slow down gradually. Doesn’t check his mirrors. Nope. He just yanks a hard left, stops abruptly, and leaves the back half of his van sticking out into the southbound lane like a rogue piece of modern art titled “Please Don’t Hit Me.”

Kaleb, mid-pass, is now in a nightmare scenario. He’s between two vehicles, the southbound lane is now blocked by the rear end of the Cintas van, and he has approximately zero options. He can’t go forward. He can’t go back. He can’t fly. So he does what no rider ever wants to do — he slams into the back of the van. Head-on. At speed. The impact knocks him unconscious. The filing doesn’t say whether he flew over the handlebars or did a full superhero roll, but we do know this: he suffered “severe and permanent injuries.” That’s not just sore muscles. That’s life-altering stuff. And all of it, according to the petition, because Jimmy Rowley treated a public roadway like his personal driveway.

So why are we in court? Because Kaleb Reno isn’t just mad — he’s suing. And not just for the medical bills, though those are surely piling up like dirty laundry at a Cintas drop-off. He’s suing on three fronts, each one juicier than the last. First up: negligence — basically, “you messed up and hurt me.” The claim says Rowley violated basic safety rules: no turn signal, reckless maneuver, creating a dangerous obstruction. But here’s the spicy part — they’re also alleging negligence per se, which is lawyer-speak for “you broke the law, so we don’t even have to argue whether you were careless — you were automatically negligent.” Then there’s negligent entrustment — a phrase so delicious it belongs on a craft cocktail menu. This one says Cintas shouldn’t have let Rowley drive at all. Maybe he’s got a history. Maybe he failed his driver training. Maybe he once tried to parallel park a forklift. We don’t know — but the implication is clear: Cintas handed the keys to someone who shouldn’t have had them. And finally, negligent hiring, training, screening, and supervision — which sounds like a PowerPoint slide from HR hell. This claim goes after Cintas itself, saying the company didn’t do its due diligence. Did they check Rowley’s driving record? Did they train him on basic traffic laws? Did they ever watch a single episode of Defensive Driving Simulator: The Series? Apparently not enough.

Now, what does Kaleb want? A cool $75,000 — and possibly more. That number might sound like a lot if you’re used to arguing over $20 at a yard sale, but in personal injury land, it’s not exactly “yacht money.” We’re talking medical bills, lost wages, pain and suffering, future care — and the filing emphasizes that the injuries are permanent. So $75K isn’t some random number; it’s a starting point. And get this — Kaleb is also asking for punitive damages. That means he doesn’t just want to be made whole — he wants to punish Cintas. He wants the court to say, “Hey, multi-billion-dollar corporation, you didn’t just mess up — you acted with reckless disregard for human life, and now you’re gonna feel it in your quarterly earnings.” That’s the nuclear option in civil court. It’s not about fairness — it’s about sending a message. And the message is: “Your employee turned a delivery run into a demolition derby.”

So what’s our take? Look, traffic accidents happen. Left turns go wrong. People misjudge distances. But this? This feels like a perfect storm of corporate complacency and individual inattention. The most absurd part? That a company as big and safety-conscious as Cintas — the same folks who sell fire safety equipment — might now be on the hook because one of their drivers treated a public road like a private parking lot. And let’s be honest — if this had been a little white sedan, we might not be talking. But it wasn’t. It was a Cintas van. Bright colors. Company logo. Rolling billboard of corporate responsibility. And yet, here we are. A motorcyclist is permanently injured. A jury trial is demanded. And somewhere, a Cintas exec is sweating over a deposition question: “Did you really think this guy should be driving?”

We’re rooting for accountability. Not just for Kaleb — who was doing everything right — but for every rider, every driver, every person who shares the road with a 5,000-pound van operated by someone who might not have been trained, screened, or supervised properly. This isn’t just about $75,000. It’s about making sure the next Cintas driver doesn’t turn a left without looking — or worse, without even signaling. Because in the grand theater of civil court, sometimes the most dramatic cases aren’t about murder or fraud — they’re about a van, a turn, and a moment that changed everything.

(And seriously, Cintas — maybe add “don’t block oncoming traffic while turning” to the employee handbook?)

Case Overview

$75,000 Demand Jury Trial Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$75,000 Monetary
$1 Punitive
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Negligence/Negligence Per Se Plaintiff alleges Defendant's employee was operating a commercial vehicle recklessly and caused a collision, resulting in severe injuries to Plaintiff.
2 Negligent Entrustment Plaintiff alleges Defendant entrusted their vehicle to a negligent driver, causing the collision.
3 Negligent Hiring, Training, Screening & Supervision Plaintiff alleges Defendant was negligent in hiring, training, screening, and supervising their employee.

Petition Text

1,472 words
IN THE DISTRICT COURT OF MCCLAIN COUNTY STATE OF OKLAHOMA KALEB RENO, Plaintiff, v. JIMMY ROWLEY, and CINTAS CORPORATION NO. 2 Defendants. PETITION COMES NOW the Plaintiff, Kaleb Reno, for their cause of action against the Defendants, Jimmy Rowley and their employer, Cintas Corporation NO. 2, alleges and states as follows: 1. Plaintiff Kaleb Reno is an individual and citizen of the State of Oklahoma. 2. Defendant Jimmy Rowley is an employee of Cintas Corporation NO. 2, and a resident and citizen of the State of Oklahoma. 3. Defendant Cintas Corporation NO. 2 is a foreign corporation registered to do business in the State of Oklahoma, with its principal place of business in Nevada. 4. That this Court has jurisdiction of the parties hereto and venue is proper in McClain County with this accident occurring within this county. OBJECT AND NATURE OF ACTION 5. This is an action by Plaintiff to recover actual damages and punitive damages for the negligence, gross negligence, and willful and wanton disregard for safety of others by Defendant Cintas Corporation NO. 2 and its employee Jimmy Roweley. Such conduct resulted in a vehicle driven by Defendant’s employee, Jimmy Rowley, to collide with Plaintiff’s vehicle. 6. That collision occurred on or about 06/27/2024, in Newcastle, Oklahoma. SAFETY RULES THAT MUST BE FOLLOWED 7. Drivers of commercial motor vehicles must always be aware of what is happening on the roads around them, to protect everyone on and near the road from serious injuries or death. 8. Drivers of commercial motor vehicles must always have proper working rear lights and reflective tape on their vehicles to avoid creating a hazard to protect everyone on and near the roads from serious injuries or death. 9. Drivers must not operate motor vehicles under the influence of alcohol or drugs, to protect everyone on and near the road from serious injuries or death. 10. Drivers must not operate motor vehicles recklessly and carelessly to protect everyone on and near the road from serious injuries or death. 11. Drivers must systematically inspect, maintain and repair their commercial vehicles, to protect everyone on and near the road from serious injuries or death. 12. The driver of any vehicle involved in an accident resulting only in damage to a vehicle which is driven or attended by any person shall immediately stop such vehicle at the scene of such accident or as close thereto as possible but shall forthwith return to and in every event shall remain at the scene of such accident until he has fulfilled the requirements of Title 47 § 10-104. 13. Businesses must properly hire, train, and supervise individuals driving their vehicles, to protect everyone on and near the road from serious injuries or death. 14. Businesses must systematically inspect, maintain and repair their commercial vehicles, to protect everyone on and near the road from serious injuries or death. 15. Businesses motor vehicles must always be in safe and proper condition at all times, to protect everyone on and near the road from serious injuries or death. 16. Businesses must not entrust their vehicles to negligent, careless, and reckless drivers to protect everyone on and near the road from serious injuries or death. FACTUAL BACKGROUND 17. That on or about June 27, 2024 in the City of Newcastle, near N. Portland Avenue and NE 16th Street, Plaintiff Reno was driving his motorcycle northbound on N. Portland Avenue which contains a single lane of traffic in either direction. 18. While driving on this road, Plaintiff Reno lawfully began passing a dumpster truck traveling in the same direction on the left-hand side with no observable oncoming traffic. 19. Defendant Cintas, through its employee and authorized driver, Defendant Rowley, was operating a large commercial van on a single-lane public roadway directly ahead of the aforementioned dumpster truck in the same northbound direction. 20. As Plaintiff Reno was passing the dumpster truck on the left-hand side, Defendant Rowely without any visible turn signal or warning, initiated a left-hand turn into a private drive from the roadway. 21. As Defendant’s vehicle turned partially into this private drive, Defendant’s vehicle came to a sudden and complete stop with the rear portion of Defendant’s vehicle protruding into the southbound lane of traffic creating a suddenly and dangerous obstruction in the roadway. 22. Plaintiff Reno still being in the process of overtaking the dumpster truck on the right-hand side, and the southbound lane of traffic obstructed by Defendant’s vehicle protruding onto the roadway, was effectively boxed in and unable to make any maneuver to avoid contact with either the dumpster truck or the Defendant’s vehicle. 23. Plaintiff Reno being unable to bring himself to a complete and sudden stop, impacted the rear driver-side portion of Defendant’s vehicle headon. 24. This collision caused severe and permanent injuries to Plaintiff Reno, resulting in him losing consciousness as a result. 25. As a direct and proximate cause of Defendant’s negligence, Plaintiff suffered severe and permanent personal injuries and damages associated with those injuries. 26. That at all times material hereto, Plaintiff was acting in a lawful, reasonable, and prudent manner. FIRST CAUSE OF ACTION: NEGLIGENCE/NEGLIGENCE PER SE 27. Defendant’s employee, Jimmy Rowley, was operating their vehicle and violated the above-referenced safety rules, and was willful and wanton in their driving on the date in question. 28. Defendant Jimmy Rowley’s should have been aware that there was a substantial and unnecessary risk that his conduct would cause serious harm to Plaintiff and other drivers by bringing his vehicle to a stop and causing an obstruction in the oncoming lane of traffic. 29. That pursuant to the doctrine of respondeat superior, Defendant Cintas Corporation NO. 2 is strictly liable for the negligence of its employee, Jimmy Rowley. 30. Defendant Cintas Corporation NO. 2 and the driver employed by Defendant were also negligent per se given the violation of state and federal statutes, ordinances, and regulations. SECOND CAUSE OF ACTION – NEGLIGENT ENTRUSTMENT 31. At the time of the collision, the company vehicle owned by Cintas Corporation NO. 2, was being driven by their employee, Jimmy Rowley. 32. Prior to the collision, Defendant Cintas Corporation NO. 2 gave that employee permission to drive said company vehicle. 33. At the time of the collision, Defendant Jimmy Rowley was driving the company vehicle while in the course and scope of their employment with Defendant Cintas Corporation NO. 2. 34. Defendant Cintas Corporation NO. 2 had the right, ability, and obligation to permit or prohibit the use of the company vehicle driven by their employee on public roadways. 35. Defendant Cintas Corporation NO. 2 had a duty to ensure that employee was a safe and prudent driver before allowing him to drive their vehicle on public roadways. 36. Defendant Cintas Corporation NO. 2 was negligent and reckless in allowing their employee to drive the subject vehicle on public roadways in an unlawful and reckless manner. 37. Defendant Cintas Corporation NO. 2’s negligent entrustment of their vehicle to their employee inflicted serious injuries and damages upon Plaintiff. THIRD CAUSE OF ACTION – NEGLIGENT HIRING, TRAINING, SCREENING & SUPERVISION 38. Defendant Cintas Corporation NO. 2 was negligent in its hiring, training, screening and/or supervision of their employee, Jimmy Rowley. DAMAGES 39. Defendant Cintas Corporation and Defendant Rowley's conduct was in reckless disregard for the rights and safety of others, including Plaintiff, and that such conduct justifies the imposition of punitive damages to fullest extent permitted under 23 O.S. §9.1. 40. Pursuant to the provisions of 12 O.S. §3226, Plaintiff submits this preliminary computation of damages sought in this lawsuit. Plaintiff advises that all damages recoverable by law are sought, including, but not limited to, those listed in OUJI 4.1. These items are among the elements for the jury to consider. Other than the amount which Plaintiff has specifically identified, Plaintiff is unable to guess or speculate as to what amount of damages a jury might award. The elements for the jury to consider in fixing the amount of Plaintiff's damages include the following: A. Plaintiff's physical pain and suffering, past and future; B. Plaintiff's mental pain and suffering, past and future; C. Plaintiff's age; D. Plaintiff's physical condition immediately before and after the accident; E. The nature and extent of Plaintiff's injuries; F. Whether the injuries are permanent; G. The physical impairment; H. The disfigurement; I. Loss of earnings; J. Impairment of earning capacity; K. The reasonable expenses of Plaintiff's necessary medical care, treatment and services, past and future. 41. In addition to the personal injuries suffered, Plaintiff seeks all damages recoverable by law to their personal property caused by Defendants' negligence. WHEREFORE, Plaintiff prays for judgement against the Defendants for the acts and omissions referenced above in excess of $75,000.00, together with interest and costs in this action which are deemed appropriate. Furthermore, Plaintiff prays judgement for punitive damages against the Defendants herein, together with interest and costs in this action as deemed appropriate. Respectfully submitted, ANDREW DAVIS Andrew Davis, OBA #34574 James Thompson, OBA #36276 Avishan Saroukhani, OBA #36779 Law Offices of Daniel M. Davis 300 N. Walnut Ave Oklahoma City, Oklahoma 73104 Telephone: (405) 602-6321 Facsimile: (405) 235-4954 [email protected] ATTORNEY FOR PLAINTIFF JURY TRIAL DEMANDED ATTORNEY LIEN CLAIMED
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