CJ-2026-16 - Dakota C. Low v. Moran Equipment, LLC

What's This Case About?

Let’s get one thing straight: a man who pleaded guilty to a felony for fleeing the scene of an injury crash is now suing his employer for giving him the keys to a massive oilfield truck — and claims they should’ve known better. Yes, you read that right. The guy who once ran from a wreck is now in court saying, “Hey, you shouldn’t have trusted me with a 20-ton vehicle!” If this were a sitcom, we’d accuse the writers of trying too hard. But no — this is real life, Canadian County style.

Meet Dakota C. Low, the plaintiff, a Canadian County resident who, on May 7, 2024, was driving along S. Rock Island Road in El Reno when — BAM — he got plowed into by a commercial motor vehicle. The driver? Omar Lozano, a man employed by Moran Equipment, LLC, a company based in Elk City that hauls oilfield gear across state lines. Now, if this were just a routine fender-bender with a distracted driver, we’d file it under “Tuesday.” But oh, this case is so much more. Because Lozano isn’t just some guy who drifted into the wrong lane. He’s a convicted felon — specifically, he pled guilty in 2019 to Leaving the Scene of an Accident Involving Injury, a felony under Oklahoma law. That’s right — five years before this crash, he was caught fleeing from another crash where someone got hurt. And yet, Moran Equipment hired him anyway, handed him the keys to a commercial behemoth, and sent him rolling down Oklahoma’s highways like he was some kind of responsible road warrior.

According to the lawsuit, Lozano wasn’t just driving recklessly — he was allegedly on his phone, distracted, failing to keep a proper lookout, and basically treating public roads like his personal demolition derby track. The petition claims he failed to stop for traffic, didn’t maintain a safe distance, and was operating “in a reckless, careless, or wanton manner.” And get this — Moran Equipment wasn’t exactly a paragon of safety compliance. The Federal Motor Carrier Safety Administration’s data shows the company had a driver out-of-service rate of 50% — meaning half the time their drivers were inspected, they were pulled off the road for violations. That’s eight times the national average. Their vehicle out-of-service rate? Also 50%. Double the national average. This isn’t a few bad apples — this is a whole orchard of rot.

So how does a company with that kind of safety record end up employing a guy with a felony hit-and-run conviction? That’s the $75,000 question — literally. Dakota Low, who says he suffered serious injuries, pain, suffering, and mounting medical bills, isn’t just suing Lozano. He’s going after Moran Equipment for what’s called negligent entrustment — a legal way of saying, “You gave a dangerous tool to a dangerous person, and of course something exploded.” Under federal law, motor carriers are required to do background checks, verify qualifications, and ensure their drivers aren’t ticking time bombs behind the wheel. But according to the filing, Moran didn’t do its homework. They allegedly failed to investigate Lozano’s criminal history, didn’t train him properly on distracted driving rules (like, you know, “don’t text while hauling a 10,001-pound truck”), and had zero supervision in place to catch him breaking federal regulations. In short: they handed a loaded gun to a guy with a record and said, “Have at it.”

Now, let’s talk about what Low wants. He’s demanding over $75,000 in damages — which, in the grand scheme of personal injury cases, isn’t crazy money. It’s not a million-dollar settlement, but for a car crash that left someone with ongoing medical needs, it’s a serious ask. And here’s the kicker: he’s also seeking punitive damages. That’s not about covering medical bills — that’s about punishment. It’s the legal equivalent of slapping a company on the wrist and saying, “You didn’t just mess up — you acted like a total jerk, and we’re gonna make sure you think twice next time.” To get punitive damages, Low has to prove Moran’s behavior was more than just negligent — it was reckless or even malicious. And with a 50% out-of-service rate and a known felon behind the wheel? That argument might have legs.

Now, here’s where things get deliciously absurd. The guy being sued — Omar Lozano — is the same guy who already proved he can’t be trusted after a crash. He fled the scene of an injury accident once. Now, he allegedly caused another one. And instead of facing consequences for his actions, his employer is being dragged into court for handing him the keys. Look, we’re not saying Lozano gets a free pass — he absolutely bears responsibility. But the irony is thicker than Oklahoma gravy. A man with a documented pattern of fleeing crashes is now the reason someone else is suing for safety violations. It’s like a horror movie where the monster sues the lab for giving him superpowers.

And yet — and yet — there’s something weirdly satisfying about this case. Because while Lozano’s past is a red flag the size of a billboard, Moran Equipment had the power, the duty, and the federal regulations staring them in the face to say, “Nope, not hiring you.” They didn’t. They rolled the dice, and someone got hurt. That’s not just bad HR — that’s a threat to public safety. Every time one of their trucks hits the road with an unqualified driver, it’s a risk to everyone else sharing the highway. So while it’s wild that a felon is at the center of a lawsuit about being too dangerous to drive, the real villain here might be the company that ignored every warning sign and kept him on payroll anyway.

Bottom line? We’re not rooting for the guy with the felony hit-and-run. But we are rooting for the idea that companies can’t just shrug and say, “Oops, our driver was a disaster,” after they ignored a mountain of red flags. If this case sends a message — that employers have to actually check who they’re putting behind the wheel of a 20-ton truck — then maybe, just maybe, this whole mess will be worth it. Until then, we’ll be here, popcorn in hand, waiting to see if justice rolls in like a slow-moving oilfield rig — or gets left at the scene like a broken taillight.

Case Overview

$75,000 Demand Jury Trial Petition

Jurisdiction

District Court of Canadian County, Oklahoma

Filing Attorney

Dakota C. Low

THE LAW OFFICE OF DAKOTA LOW, P.L.L.C.

Relief Sought

$75,000 Monetary

$1 Punitive

Plaintiffs

Dakota C. Low individual
Rep: Dakota C. Low, OBA #31627, THE LAW OFFICE OF DAKOTA LOW, P.L.L.C.

Defendants

Moran Equipment, LLC business
Omar Lozano individual

Claims

#	Cause of Action	Description
1	NEGLIGENCE	Plaintiff was injured in a collision with a commercial motor vehicle driven by Defendant Lozano, who was acting within the scope of his employment with Defendant Moran.
2	NEGLIGENCE PER SE	Plaintiff alleges that Defendant Lozano's actions constituted a violation of Oklahoma's Rules of the Road.
3	NEGLIGENT ENTRUSTMENT, SUPERVISION, HIRING AND FAILURE TO TRAIN	Plaintiff alleges that Defendant Moran was negligent in entrusting the commercial motor vehicle to Defendant Lozano, who had a disqualifying criminal history and was unfit to safely operate commercial motor vehicles.
4	PUNITIVE DAMAGES	Plaintiff seeks punitive damages for Defendants' alleged malicious or reckless behavior.

Petition Text

1,750 words

IN THE DISTRICT COURT OF CANADIAN COUNTY STATE OF OKLAHOMA DAKOTA C. LOW, Plaintiff, v. MORAN EQUIPMENT, LLC, an Oklahoma limited liability company, and OMAR LOZANO, Defendants. FILED DISTRICT COURT CANADIAN COUNTY, OKLAHOMA January 6, 2026 5:29 PM HOLLY EATON, COURT CLERK Case Number CJ-2026-16 Case No. PETITION COMES NOW the Plaintiff, Dakota C. Low (hereinafter "Plaintiff"), and for his causes of action against Defendants, Moran Equipment, LLC (hereinafter "Moran") and Omar Lozano (hereinafter "Lozano") (collectively, "Defendants"), alleges and states as follows: I. PARTIES 1. Plaintiff, Dakota C. Low, is and was at all material times a resident of Canadian County, Oklahoma. 2. Defendant Moran Equipment, LLC is an Oklahoma limited liability company with its principal place of business at 319 Industrial Parkway, Elk City, Oklahoma 73644. Defendant Moran may be served through its registered agent, Joshua Moran, at 319 Industrial Parkway, Elk City, Oklahoma 73644. 3. Upon information and belief, Defendant Omar Lozano was at all material times an individual residing at 215 N. O Avenue, El Reno, Oklahoma 73036. At all times material hereto, Defendant Lozano was an agent and/or employee of Moran Equipment, LLC, acting within the course and scope of his employment, entrusted to drive a truck for Defendant Moran and was the driver of the truck at issue. Defendant Moran is therefore responsible for the actions of Defendant Lozano under the doctrine of respondeat superior. II. JURISDICTION & VENUE 4. The collision which gives rise to this cause of action occurred in Canadian County, State of Oklahoma, and therefore, this Court has proper jurisdiction and venue over this matter. III. STATEMENT OF FACTS Plaintiff adopts the previous paragraphs as if fully stated herein and further alleges: 5. On or about May 7, 2024, on a public roadway, S. Rock Island at, or about, 1501 S Rock Island, in El Reno, Canadian County, Oklahoma, Defendant Lozano negligently drove a commercial motor vehicle so as to cause a collision with the vehicle being driven by Plaintiff. 6. Upon information and belief, at all material times herein, Defendant Moran owned the commercial motor vehicle driven by Defendant Lozano, which Defendant Moran directed and authorized be operated upon Oklahoma’s roadways. 7. Upon information and belief, at all material times herein, Defendant Lozano was an agent and/or employee of Defendant Moran, entrusted to drive a commercial motor vehicle for Defendant Moran and was the driver of the commercial motor vehicle at issue. 8. At the time of the collision, Defendant Lozano was acting within the course and scope of his employment with Defendant Moran. 9. The careless, reckless and grossly negligent actions and omissions of Defendants were the direct and proximate cause of Plaintiff’s damages. 10. Defendants Moran Equipment, LLC and Omar Lozano are concurrent tortfeasors whose combined negligent acts and omissions proximately caused and contributed to Plaintiff’s injuries and damages, and are therefore jointly and severally liable to Plaintiff for all damages resulting from the collision. IV. COUNT 1 – NEGLIGENCE Plaintiff adopts the previous paragraphs as if fully stated herein and further alleges: 11. Defendant Lozano had a duty to exercise ordinary care in his operation of the commercial vehicle he was driving. 12. Defendant Lozano breached his duty of care and was negligent in one or more of the following ways: a. Failing to devote his full time and attention to driving; b. Failing to keep a proper lookout; c. Failing to operate his vehicle at a speed reasonable for the situation; or d. Failing to take a proper evasive action. 13. Defendant Lozano owed a duty to Plaintiff to operate the vehicle under his control in a safe and reasonable manner, to use care to prevent injury to other persons, such as Plaintiff. 14. Defendant Lozano breached his duty of ordinary care when he negligently operated the commercial motor vehicle he was driving and caused it to collide with the vehicle driven by Plaintiff, causing Plaintiff bodily injury. 15. As a direct and proximate result of Defendant Lozano’s negligence, Plaintiff has incurred damages for which he should be compensated. 16. Defendant Moran is vicariously liable for the negligent acts and/or omissions of its agent and employee, Defendant Lozano, through the doctrine of respondeat superior. 17. As a direct and proximate result of Defendants' negligence, Plaintiff has sustained serious bodily injuries, has experienced pain and suffering, has incurred medical expenses, and will incur future medical expenses, all in an amount in excess of $75,000.00. V. COUNT 2 – NEGLIGENCE PER SE Plaintiff adopts the previous paragraphs as if fully stated herein and further alleges: 18. In the operation of a vehicle, Defendant Lozano had a duty to follow Oklahoma's Rules of the Road, 47 O.S. § 11-101, et seq. 19. As set forth in Oklahoma's Rules of the Road, Defendant Lozano had a duty to: a. Devote his full time and attention to driving (47 O.S. § 11-901b); b. Keep a proper lookout for other vehicles; c. Maintain a safe following distance; d. Refrain from operating his vehicle in a reckless, careless, or wanton manner without regard for the safety of others (47 O.S. § 11-901(A)). 20. Plaintiff is within the class of persons the statutes are designed to protect. 21. Defendant Lozano breached his duty to Plaintiff in one or more of the following ways: a. Operating his vehicle while distracted by his cell phone; b. Failing to keep a proper lookout; c. Failing to maintain a safe following distance; d. Failing to stop for traffic; e. Operating his vehicle in a reckless, careless, or wanton manner without regard for the safety of others. 22. Defendant Lozano's failure to obey and carry out the duties imposed on him by Oklahoma's Rules of the Road directly and proximately caused the collision which injured Plaintiff, all in an amount in excess of $75,000.00. VI. COUNT 3 – NEGLIGENT ENTRUSTMENT, SUPERVISION, HIRING AND FAILURE TO TRAIN AGAINST DEFENDANT MORAN Plaintiff adopts the previous paragraphs as if fully stated herein and further alleges: 23. At all times material hereto, Defendant Moran operated as a motor carrier engaged in interstate commerce, transporting oilfield equipment using commercial motor vehicles with a gross vehicle weight rating (GVWR) in excess of 10,001 pounds, and was assigned United States Department of Transportation Number 2523292. 24. As a motor carrier operating commercial motor vehicles with a GVWR in excess of 10,001 pounds in interstate commerce, Defendant Moran and its agents and employees, including Defendant Lozano, were subject to and required to obey the Federal Motor Carrier Safety Regulations, codified at 49 C.F.R. Parts 390-399, including but not limited to: (a) 49 C.F.R. § 390.11, which provides that motor carriers are responsible for ensuring their drivers comply with the Federal Motor Carrier Safety Regulations; (b) 49 C.F.R. § 391.11, which requires motor carriers to employ only qualified drivers; (c) 49 C.F.R. § 392.14, which requires drivers to exercise caution in hazardous conditions; (d) 49 C.F.R. § 392.80, which prohibits motor carrier drivers from texting while driving a commercial motor vehicle; and (e) 49 C.F.R. § 392.82, which prohibits motor carrier drivers from using a hand-held mobile telephone while driving a commercial motor vehicle. 25. As reported by the Federal Motor Carrier Safety Administration’s Safety Measurement System, at the time of the collision giving rise to this action, Defendant Moran had a driver out-of-service rate of 50%, which was more than eight times the national average of 6.1%, and a vehicle out-of-service rate of 50%, which was more than twice the national average of 23.1%. These rates demonstrate a pattern of systemic failures in driver qualification, training, and supervision. 26. At the time Defendant Moran employed and entrusted Defendant Lozano with the subject commercial motor vehicle, Defendant Lozano had a documented criminal history that included a felony charge for Leaving the Scene of an Accident Involving Injury in Canadian County Case No. CF-2018-00599, to which he entered a guilty plea, on July 31, 2019. 27. Defendant Moran had a duty to conduct a reasonable investigation into the background, driving history, and qualifications of prospective drivers before entrusting them with commercial motor vehicles, including reviewing criminal history records and prior driving violations. 28. Defendant Moran had a duty to train its drivers on the safe operation of commercial motor vehicles and to supervise its drivers to ensure compliance with federal regulations prohibiting distracted driving, including the use of hand-held mobile telephones while operating a commercial motor vehicle in violation of 49 C.F.R. §§ 392.80 and 392.82. 29. Defendant Moran breached its duty by negligently entrusting its dangerous instrumentality, namely the commercial motor vehicle, to Defendant Lozano despite his disqualifying criminal history and unfitness to safely operate commercial motor vehicles. 30. Defendant Moran breached its duty by negligently hiring and retaining Defendant Lozano to drive the subject commercial motor vehicle without adequately investigating his criminal history, which would have revealed his guilty plea to the felony charge of Leaving the Scene of an Accident Involving Injury and demonstrated his unfitness to operate commercial motor vehicles. 31. Defendant Moran breached its duty by negligently supervising Defendant Lozano, including failing to monitor and enforce compliance with federal regulations prohibiting the use of hand-held mobile telephones while operating a commercial motor vehicle. 32. Defendant Moran breached its duty by negligently failing to train Defendant Lozano on the safe operation of commercial motor vehicles and the prohibition against distracted driving under 49 C.F.R. §§ 392.80 and 392.82. 33. Defendant Moran breached its duty by negligently failing to implement and enforce adequate policies prohibiting distracted driving by its employees operating commercial motor vehicles, as evidenced by its driver out-of-service rate of 50%, which was more than eight times the national average. 34. As a direct and proximate result of Defendant Moran’s negligence in entrusting the commercial motor vehicle to Defendant Lozano, in negligently hiring and retaining Defendant Lozano without adequate investigation, in failing to properly train Defendant Lozano, and in failing to properly supervise Defendant Lozano, Plaintiff has suffered damages and is entitled to recover actual against Defendant Moran. VII. COUNT 4 – PUNITIVE DAMAGES Plaintiff adopts the previous paragraphs as if fully stated herein and further alleges: 35. Defendants acts and omissions, by clear and convincing evidence, warrant the imposition by the court and jury of punitive damages in an amount determined in their discretion. WHEREFORE, Plaintiff, Dakota C. Low, prays for judgment against Defendants, Moran Equipment, LLC and Omar Lozano, jointly and severally, in an amount in excess of $75,000.00, as well as punitive damages, together with pre-judgment interest from the date of injury through the date of judgment at the maximum rate allowed by law, post-judgment interest at the legal rate, costs of court, and such other and further relief the Court deems equitable, just, and available to Plaintiff by law. Respectfully Submitted, Dakota C. Low, OBA #31627 THE LAW OFFICE OF DAKOTA LOW, P.L.L.C. 925 W. State Highway 152 Mustang, OK 73064 Telephone: (405) 601-8899 Facsimile: (405) 730-8083 [email protected]