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HUGHES COUNTY • CJ-2026-00020

Mary Jeanette Bartley v. Matilda King

Filed: Mar 2, 2026
Type: CJ

What's This Case About?

Let’s be clear: this is not a story about a dog getting loose. This is not a tale of a split-second mistake or a tragic accident. This is the story of a woman who was bitten by a dog that had been chained — in her own backyard — by her neighbors — without her permission — while she was just standing on her own property minding her own business. And somehow, the dog’s owners claim they didn’t hear a thing. A dog attack. In someone else’s yard. That they set up. And didn’t notice. If this were a horror movie, the neighbors would be the final twist — the quiet couple next door who’ve been burying bodies in the garden for years. But no, this is real life. In Holdenville, Oklahoma. And the plaintiff, Mary Jeanette Bartley, is suing for $75,000 — and honestly? We’re not even mad about it.

So who are these people? On one side, we’ve got Mary Jeanette Bartley — a resident of Hughes County, just trying to live her life in peace. She owns a house. She has a backyard. She presumably enjoys things like fresh air, gardening, or just stepping outside without being mauled. On the other side? We’ve got not one, not two, but four defendants: Matilda King, Robert King, Amber Marie Roberts, and Kevin Roberts. Now, the filing doesn’t spell out their relationships, but given the surnames, we’re guessing this is a family affair — possibly two couples, possibly parents and in-laws, possibly just a whole lot of people who collectively thought it was fine to chain a dog to a wooden spool in someone else’s yard. And not just any yard — the yard of the woman who’s now suing them. The level of audacity here is almost impressive. It’s like they treated Mary’s property like a community dog park with no rules, no permission, and zero liability.

Now, let’s walk through what actually happened, because it reads like a sitcom plot gone horribly wrong. On September 12, 2025 — a perfectly normal day in Holdenville — Mary was in her own backyard. Not trespassing. Not snooping. Not provoking dogs. Just… being in her yard. Then, out of nowhere, a dog — owned and harbored by the Kings and the Roberts — comes barreling out from under a trailer in the neighboring driveway. But here’s the kicker: the dog wasn’t just loose. It was chained — tethered to a large wooden spool… that was located in Mary’s backyard. That’s right. These people didn’t just fail to secure their dog. They physically anchored it — like a medieval siege weapon — on someone else’s property. And the chain was long enough for the dog to roam freely across Mary’s entire yard. So when she stepped outside, she wasn’t just in the danger zone — she was in the target zone. The dog attacked without provocation, biting her multiple times, leaving severe lacerations and puncture wounds on her legs. She needed an ambulance. She needed emergency treatment. She needed antibiotics. She needed therapy, probably. And she definitely needed a new set of pants.

When the cops showed up — both the Hughes County Sheriff’s Office and the Holdenville Police Department — they did what cops do: they investigated. They classified the incident as “Animal Bites” (code 86C, for all you true crime nerds). They interviewed the owners. And here’s where it gets deliciously absurd: the defendants claimed they didn’t hear anything. Not the barking. Not the screaming. Not the chaos of a full-on dog attack happening in the next yard over. Nothing. Nada. Zilch. Meanwhile, animal control shows up, confirms the dog bit someone, and because the shelter is full, they tell the owners: “Cool, just quarantine the dog yourselves for ten days.” Which, sure, if you’re the kind of person who thinks a dog that attacks strangers in neighboring yards is just misunderstood. Oh, and by the way — the city also charged the owners with intrusion on private property, because — and this is wild — you can’t just put your dog on someone else’s land without asking. Who knew?

Legally, Mary’s got two solid claims. First: strict liability. Oklahoma has a dog bite law — Section 42.1 — that says if your dog bites someone who’s lawfully on property (like, say, their own backyard), and they didn’t provoke it (like, say, by not doing anything at all), then you’re on the hook. No need to prove negligence. No need to show the dog had a history of violence. No need to argue about whether the dog was “just excited.” If it bites, you pay. Full stop. And the courts have said this law should be liberally construed — meaning, if there’s any doubt, lean toward protecting the victim. And Mary was on her own property. The dog was chained there without her consent. The bite was unprovoked. The elements? Check, check, check, check.

Second claim: negligence. Because apparently, one legal theory isn’t enough when your neighbors treat your yard like a canine staging ground. Here, Mary argues the owners failed to control their dog — they chained it too close to her property, with too long a chain, with no fence, no supervision, no basic common sense. They violated city ordinances. They created a foreseeable risk. And boom — attack happens. So even if strict liability didn’t apply (it does), they’re still liable for being, frankly, terrible dog owners.

Now, about that $75,000. Is it a lot? Is it too much? Let’s break it down. We’re talking emergency ambulance transport, medical treatment, possible surgeries, antibiotics for infection, ongoing care for scarring, lost wages if she couldn’t work, and — let’s not forget — the psychological toll of being attacked by a dog that was anchored to your own yard like a cursed garden ornament. Therapy isn’t cheap. Neither is peace of mind. And $75,000 isn’t even the full cost — the filing says “in excess of” that amount, meaning it could be more. But even at $75k, it’s not some outrageous windfall. It’s not buying a house. It’s not retiring to Belize. It’s covering real damages for a preventable, deeply violating incident. And let’s be honest — if these people had just built a proper fence, or kept their dog on their own property, or, I don’t know, listened to it barking during a violent attack, none of this would’ve happened.

Our take? The most absurd part isn’t even the attack. It’s the sheer gall of chaining a dog to someone else’s yard and then acting shocked when it bites them. It’s the “we didn’t hear anything” defense, which might be the weakest alibi since “the dog ate my homework.” It’s the fact that the dog was quarantined by the owners — like letting a suspect guard themselves. And it’s the quiet implication that Mary was somehow responsible for being in her own home. She wasn’t. She had every right to be there. The dog didn’t. The owners didn’t. And now, they’re all on the hook — jointly and severally — for what should’ve been avoided with five minutes of basic responsibility.

We’re rooting for Mary. We’re rooting for the principle that your backyard isn’t a community dog tether zone. And we’re rooting for the idea that in 2026, people should know better than to treat their pets like booby traps. If this case goes to trial — and they’re demanding a jury — we hope the verdict is loud, clear, and comes with a side of poetic justice. And maybe, just maybe, a new law: “Thou shalt not chain thy dog to thy neighbor’s spool.”

Case Overview

$75,000 Demand Jury Trial Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$75,000 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Strict Liability Oklahoma dog bite statute claim
2 Negligence Negligence claim for failure to properly restrain and control dog

Petition Text

1,351 words
IN THE DISTRICT COURT OF HUGHES COUNTY STATE OF OKLAHOMA MARY JEANETTE BARTLEY, Plaintiff, vs. MATILDA KING, ROBERT KING, AMBER ROBERTS and KEVIN ROBERTS Defendants. Case No. CJ-2026-80 PETITION COMES NOW Plaintiff, Mary Jeanette Bartley, and for her causes of action against Defendants and/or each of them, alleges and states as follows: 1. Plaintiff, Mary Jeanette Bartley, is a resident and citizen of Hughes County, Oklahoma. 2. Defendant Matilda King is a resident and citizen of Hughes County, Oklahoma. 3. Defendant Robert King is a resident and citizen of Hughes County, Oklahoma. 4. Defendant Amber Marie Roberts is a resident and citizen of Hughes County, Oklahoma. 5. Defendant Kevin Roberts is a resident and citizen of Hughes County, Oklahoma. 6. At all times relevant hereto, Defendants and/or each of them were the owners, keepers, and/or harborers of a dog, as that term is broadly construed under Oklahoma law. This Court has jurisdiction over this matter pursuant to the laws of the State of Oklahoma. 7. Venue is proper in Hughes County, Oklahoma, as the incident giving rise to this action occurred within Hughes County, and all parties reside within Hughes County. FACTS 8. On September 12, 2025, Plaintiff was on her own property in Holdenville, Hughes County, Oklahoma — a place where she had a lawful right to be. 9. Prior to the attack, Defendants and/or each of them had chained and/or tethered their dog to a large wooden spool located in Plaintiff's backyard, without Plaintiff's permission or knowledge. Plaintiff did not authorize Defendants and/or each of them to place, chain, or tether the dog on her property. 10. The dog owned and/or harbored by Defendants and/or each of them, while chained to said spool in Plaintiff's backyard, ran out from underneath a trailer located in the neighboring driveway. The chain on the dog was of sufficient length to reach the entirety of Plaintiff's yard, and the dog, without provocation, viciously attacked and bit Plaintiff, causing severe lacerations and other injuries to Plaintiff's legs. 11. The attack was investigated by both the Hughes County Sheriff's Office (Case No. 2025-0389) and the Holdenville Police Department (Case No. 2025-622). Both agencies classified the incident as 86C — Public Peace — Animal Bites. Both agencies identified Defendants and/or each of them as the offenders/suspects and Plaintiff as the victim. 12. According to the investigating officers, Defendants and/or each of them stated they did not hear anything during the attack and did not know what had happened until emergency services arrived. 13. The Holdenville Animal Control Officer responded and documented the incident as a dog bite. Because the animal shelter was full, Defendants and/or each of them were directed to personally quarantine the dog at their residence for 10 days. 14. The Holdenville Police Department charged Defendants and/or each of them with Intrusion on Private Property in violation of Section 136.06 of the Holdenville City Ordinance arising from their dog's unpermitted presence on Plaintiff’s property. COUNT I: STRICT LIABILITY 15. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 14 above. 16. Oklahoma Statutes Title 4, Section 42.1 provides: "The owner or owners of any dog shall be liable for damages to the full amount of any damages sustained when his dog, without provocation, bites or injures any person while such person is in or on a place where he has a lawful right to be." 17. Oklahoma's dog bite statute is derived from the common law and is liberally construed to promote its object. Marshall v. City of Tulsa, 558 P.3d 1220, 1226 (Okla. 2024); Nickell v. Sumner, 943 P.2d 625, 628 (Okla. 1997); 12 O.S. § 2. The statute imposes liability without regard to fault. Marshall, 558 P.3d at 1226; Nickell, 943 P.2d at 627. 18. To recover under Section 42.1, a plaintiff must establish four elements: (1) ownership of the dog by the defendant; (2) lack of provocation by the victim; (3) a bite or other injury to the plaintiff by the dog; and (4) the plaintiff's lawful presence at the place where the attack occurred. Marshall v. City of Tulsa, 558 P.3d 1220, 1226 (Okla. 2024); Hampton By and Through Hampton v. Hammons, 743 P.2d 1053, 1058 (Okla. 1987); Nickell v. Sumner, 943 P.2d 625, 628 (Okla. 1997). 19. All four elements are satisfied in this case: a) Defendants and/or each of them owned, kept, and/or harbored the dog that attacked Plaintiff, as confirmed by the police investigation, animal control records, and the Impounded Dog Information Sheet, which identifies Defendants and/or each of them as the dog's owner. Both the Holdenville Police Department and the Hughes County Sheriff’s Office identified Defendants and/or each of them as the offenders responsible for the dog; b) Plaintiff did nothing to provoke the attack. Defendants and/or each of them had chained the dog to a spool in Plaintiff’s own backyard without her permission, and the dog attacked Plaintiff without provocation; c) The dog owned and/or harbored by Defendants and/or each of them bit and severely injured Plaintiff, causing lacerations and other injuries requiring emergency medical transport and extensive medical treatment; and d) Plaintiff was on her own property at the time of the attack — a place where she unquestionably had a lawful right to be. There is a strong public policy in Oklahoma that "one who chooses to harbor a dog should be responsible for unprovoked attacks of the animal." Hampton By and Through Hampton v. Hammons, 743 P.2d 1053, 1059 (Okla. 1987). The Oklahoma Supreme Court has reaffirmed this principle, holding that matters concerning dog attacks reflect a concurrent local and state concern and that the dog bite statute is to be liberally construed to protect persons injured by dogs. Marshall v. City of Tulsa, 558 P.3d 1220, 1226–27 (Okla. 2024). 20. Defendants and/or each of them are therefore strictly liable to Plaintiff for the full amount of damages sustained as a result of the dog attack. COUNT II: NEGLIGENCE 21. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 20 above. 22. In the alternative, and in addition to their strict liability, Defendants and/or each of them owed a duty to Plaintiff and the public to exercise reasonable care in the keeping, restraint, and control of their dog so as to prevent it from attacking, biting, or injuring others. 23. Defendants and/or each of them breached that duty by, among other things: a) Chaining and/or tethering their dog to a spool located in Plaintiff's backyard without Plaintiff's knowledge or permission; b) Failing to properly restrain, confine, or control their dog; c) Allowing their dog to be tethered with a chain of sufficient length to reach Plaintiff and to roam to areas beyond Defendants' property; d) Failing to maintain adequate fencing or other enclosures to prevent the dog from accessing Plaintiff's property; and e) Failing to comply with applicable animal control ordinances of the City of Holdenville. 24. As a direct and proximate result of Defendants' and/or each of their negligence, their dog attacked Plaintiff and caused her serious bodily injuries and damages. DAMAGES 25. As a direct and proximate result of the dog attack described herein, Plaintiff has suffered and continues to suffer the following injuries and damages: a) Severe lacerations and puncture wounds to her legs requiring emergency medical treatment; b) Subsequent infection and complications requiring additional medical treatment; c) Emergency medical transport by ambulance from the scene; d) Past and future medical expenses; e) Past and future lost wages and loss of earning capacity; f) Physical pain and suffering, both past and future; g) Mental anguish, emotional distress, fear, and anxiety, both past and future; h) Permanent scarring and disfigurement; i) Such other damages as may be shown at trial. PRAYER FOR RELIEF WHEREFORE, Plaintiff, Mary Jeanette Bartley, respectfully prays for judgment against Defendants, Amber Marie Roberts, Kevin Roberts, Matilda King and Robert King, jointly and severally, as follows: a) For actual and compensatory damages in an amount in excess of $75,000.00; b) For costs of this action; c) For pre-judgment and post-judgment interest as allowed by law; d) For such other and further relief as this Court deems just and proper. Respectfully submitted, Tim Maxcey, OBA # 15567 Halee Simpson, OBA # 36255 Stipe Law Firm 343 East Carl Albert Pkwy P. O. Box 1369 McAlester, Oklahoma 74502 (918) 423-0421 (918) 423-0266 (facsimile) [email protected] [email protected] Attorneys for Plaintiff ATTORNEYS LIEN CLAIMED
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