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WAGONER COUNTY • CJ-2026-00098

McKenzie Richmond v. Ethan Payne

Filed: Mar 5, 2026
Type: CJ

What's This Case About?

Let’s get one thing straight: nobody expects to fly out of their own moonroof on the Muskogee Turnpike like some kind of accidental superhero, but here we are. On June 6, 2025, McKenzie Richmond wasn’t auditioning for a car commercial — she was just driving eastbound, minding her own business, when she suddenly became a human projectile launched through the glass ceiling of her car. Ejected. Through the moonroof. In a highway collision caused by a U-Haul trailer parked like a landmine in the middle of the road. Now, she’s suing for $150,000, and honestly? After reading this filing, you might want to throw a fundraiser.

So who are these people? On one side, we’ve got McKenzie Richmond, a resident of Muskogee County, Oklahoma — a regular driver, presumably with a taste for fresh air and possibly questionable roof-opening decisions. She’s represented by Smolen Law, PLLC, a firm that seems to specialize in making insurance adjusters sweat. On the other side? Ethan Payne, a Tulsa County man who, on that fateful day, was hauling a U-Haul trailer and apparently also hauling bad judgment. And then there’s Tiffany Snodgrass, whose current whereabouts are unknown — which, let’s be honest, might be the most relatable thing about her. She’s allegedly the owner of the vehicle Payne was driving, and she’s now tangled in this mess not because she was behind the wheel, but because she may have handed the keys to someone who should’ve been benched.

Here’s how this highway horror story went down. Ethan Payne was driving east on the Muskogee Turnpike, pulling a U-Haul trailer, when — plot twist — his rig had mechanical issues. Okay, fair enough. Stuff breaks. But instead of fully pulling over like a responsible adult with a giant trailer attached to his car, Payne did what can only be described as a half-effort: he parked the vehicle partially on the roadway. Not off to the shoulder. Not in a safe zone. Nope. Part of that U-Haul was still sitting in the traveled portion of the highway, like a trap set by someone who’s never taken a driver’s ed class or watched any episode of Highway to Heaven.

Now imagine you’re McKenzie Richmond, cruising along at highway speed, probably listening to Lizzo or maybe just the hum of your engine, when — BAM — you don’t see the partially obstructing trailer until it’s too late. You collide. Your car rolls off the road. And in what can only be described as a perfect storm of poor design and worse decisions, you are ejected through the moonroof. Let that sink in. Not the door. Not the windshield. The moonroof. That thing you open to let in a breeze or show your dog the stars? It just became your exit ramp. The filing doesn’t say whether she landed in a hayfield or on a passing UFO, but it does confirm she sustained “serious bodily injury.” Which, yeah. No kidding.

Now, why are we in court? Because McKenzie Richmond isn’t just mad — she’s legally mobilized. Her lawsuit lays out three claims, and they’re not messing around. First up: Negligence (and Negligence Per Se) against Ethan Payne. In plain English? He had a duty to drive safely and park responsibly. He failed. Not only did he leave his trailer in the roadway, but he violated Oklahoma law — specifically 47 O.S. § 11-1001(A)(1), which says you can’t park on the main part of a highway if you can reasonably pull off. And if you do stop, you better leave enough room for other cars to pass and be visible from 400 feet away. Payne didn’t do any of that. So under Oklahoma law, his actions aren’t just dumb — they’re automatically negligent. That’s what “negligence per se” means: break the law, cause an accident, and boom — liability is basically baked in.

Second claim: Negligent Entrustment — and this one’s aimed at Tiffany Snodgrass. Now, this is the legal equivalent of blaming the person who lent their car to the guy who crashed it. The idea here is that if you give your vehicle to someone you know is a terrible driver — reckless, careless, the kind of person who parks trailers in traffic — and they hurt someone, you can be on the hook too. The filing says Snodgrass “knew or should have known” Payne was a bad driver. We don’t have receipts on that yet — the plaintiff admits this will be confirmed in discovery — but if they can prove Payne has a history of sketchy driving, Snodgrass might regret ever saying, “Sure, take my car, Ethan.”

Third and final claim: Punitive Damages — the legal version of throwing shade with a side of financial vengeance. This isn’t about covering medical bills. This is about punishment. The filing alleges Payne and Snodgrass acted with “intentional, wanton, and reckless conduct” — meaning they either didn’t care or knew their actions could cause serious harm. If proven, punitive damages are meant to slap wallets and send a message: “Don’t do stupid s* on the highway.” And honestly? It’s hard to argue with that sentiment.

So what does McKenzie want? $150,000. Split right down the middle: $75,000 in actual damages (medical bills, car repairs, lost wages, pain and suffering), and another $75,000 in punitive damages. Is that a lot? For a car accident with ejection via moonroof — absolutely not. Medical bills alone can skyrocket into six figures, and if she’s dealing with long-term injuries, PTSD, or can’t work for a while, $75K in actual damages might even be conservative. The punitive half? That’s the spicy part. It’s not about fairness — it’s about accountability. And in a case where someone left a U-Haul sticking out into traffic like a deadly speed bump, a financial sting might be the only thing that changes behavior.

Now, our take? Look, we’ve covered lawsuits over stolen chickens, broken fingernails, and one guy who sued his ex for “emotional distress” caused by a poorly timed TikTok. But this one? This one’s next-level. The image of someone being launched through a moonroof is equal parts tragic and absurd — like a Jackass stunt gone wrong, except nobody’s laughing. The most absurd part? That Ethan Payne thought it was okay to park a U-Haul partially on a highway. Not fully off. Not safely visible. Just… kind of there. Like a forgotten lawn chair at a concert. And the fact that Tiffany Snodgrass is currently MIA? It adds a Gone Girl vibe to what’s otherwise a textbook case of highway negligence.

But here’s what we’re rooting for: accountability. Not just because someone flew through a moonroof — though that’s certainly memorable — but because this is a reminder that small decisions have massive consequences. A few extra seconds to pull fully off the road could’ve prevented all of this. A second thought before lending your car to a risky driver might’ve helped too. We’re not saying everyone needs to live in fear of lawsuits, but maybe — just maybe — don’t treat the Muskogee Turnpike like your personal driveway.

And seriously, if you’re going to have a moonroof? Maybe keep it closed during rush hour.

Case Overview

$150,000 Demand Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$75,000 Monetary
$75,000 Punitive
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Negligence/Negligence Per Se Plaintiff alleges Defendant Ethan Payne was negligent in driving and leaving his vehicle parked in the roadway, causing a collision and injuries to Plaintiff.
2 Negligent Entrustment Plaintiff alleges Defendant Tiffany Snodgrass was negligent in entrusting her vehicle to Defendant Ethan Payne, who was a careless and incompetent driver.
3 Punitive Damages Plaintiff seeks punitive damages against both Defendants, alleging their intentional, wanton, and reckless conduct caused harm to Plaintiff.

Petition Text

963 words
IN THE DISTRICT COURT IN AND FOR WAGONER COUNTY STATE OF OKLAHOMA MCKENZIE RICHMOND; an Individual, Plaintiff, v. ETHAN PAYNE; and TIFFANY SNODGRASS; Individuals, Defendants. Case No. C J-2026-0098 Honorable Judge: Hunter ATTORNEY LIEN CLAIMED PETITION COMES NOW the Plaintiff McKenzie Richmond, through counsel, SMOLEN LAW, PLLC, and for her causes of action against the Defendants Ethan Payne and Tiffany Snodgrass (collectively ("Defendants"), states as follows: PARTIES, JURISDICTION, AND VENUE 1. Ms. Richmond is and was at all times relevant hereto a resident of Muskogee County, Oklahoma. 2. Mr. Payne is a resident of Tulsa County, Oklahoma. 3. At the time of this filing, Ms. Snodgrass’s residence is presently unknown. 4. The acts, occurrences, and omissions complained of herein occurred in Wagoner County, Oklahoma. 5. Venue is appropriate in this Court because a substantial part of the acts, occurrences, and omissions giving rise to the claims occurred within the confines of Wagoner County, Oklahoma. 6. This Court has jurisdiction over the parties hereto and the subject matter of this controversy. The amount in controversy exceeds Seventy-Five Thousand Dollars ($75,000.00). FACTS COMMON TO ALL CAUSES OF ACTION 7. Paragraphs 1-6 are incorporated herein by reference. 8. On or about June 6, 2025, Ms. Richmond and Mr. Payne were both traveling eastbound the Muskogee Turnpike near Mile Marker 1. 9. Mr. Payne was pulling a U-Haul trailer and experienced mechanical issues. 10. Mr. Payne pulled to the side of the road; however, he did not fully pull the trailer off the roadway. 11. Ms. Richmond did not see the U-Haul trailer parked in the roadway and collided with it, causing her vehicle to roll off the roadway ("Accident"). 12. As a result of the Accident, Ms. Richmond was ejected through the moonroof of her vehicle and sustained serious bodily injury. 13. Upon information and belief, Ms. Snodgrass is the owner of the vehicle driven by Mr. Payne. 14. As a result of Mr. Payne's negligent operation of the vehicle, Ms. Richmond sustained significant injuries to her person. 15. Ms. Snodgrass was negligent in entrusting the vehicle to Mr. Richmond. CAUSES OF ACTION COUNT I. NEGLIGENCE/NEGLIGENCE PER SE (Mr. Payne) 16. Paragraphs 1 - 15 are incorporated herein by reference. 17. Mr. Payne owed a duty to Ms. Richmond, and all other drivers on the roadway to operate the vehicle he was driving in a safe and reasonable manner, to use ordinary care to prevent injuries to other persons, obey pertinent traffic signals, and to keep a lookout consistent with the safety of others. 18. By operating the vehicle he was driving in such a way, and by leaving a portion of his vehicle parked in the roadway. In a dangerous manner and with complete disregard for the health and well-being of Ms. Richmond and all other drivers on the roadway, Mr. Payne breached the duty owed to Ms. Richmond. 19. Under Oklahoma law, "[u]pon any highway outside of a business or residence district no person shall stop, park or leave standing any vehicle, whether attended or unattended, upon the paved or main-traveled part of the highway when it is practicable to stop, park or so leave such vehicle off such part of said highway, but in every event an unobstructed width of the highway opposite a standing vehicle shall be left for the free passage of other vehicles and a clear view of such stopped vehicles shall be available from a distance of four hundred (400) feet in each direction upon such highway." 47 O.S. § 11-1001(A)(1). 20. By leaving his vehicle parked in the roadway, Mr. Payne violated Oklahoma law and his duty to Ms. Richmond. 21. Mr. Payne’s actions constitute negligence per se. 22. Mr. Payne’s breach was the actual and proximate cause of Ms. Richmond’s injuries. 23. As a result of Mr. Payne’s negligence, Ms. Richmond has suffered personal injury, including medical expenses, property damage, mental and physical pain and suffering, loss of wages, and other actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00). COUNT II – NEGLIGENT ENTRUSTMENT (Ms. Snodgrass) 24. Paragraphs 1 - 23 are herein incorporated by reference. 25. Upon information and belief to be confirmed through discovery, Ms. Snodgrass owned the vehicle that Mr. Payne was driving at the time of the Accident. 26. Upon information and belief to be confirmed through discovery, Ms. Snodgrass allowed Mr. Payne to operate the vehicle when Ms. Snodgrass knew, or should have known, that Mr. Payne was a careless, reckless, and incompetent driver. 27. Ms. Richmond incurred a loss as a result of Ms. Snodgrass’s careless, reckless, and incompetent behavior. 28. As a direct and proximate result of Ms. Snodgrass’s acts and omissions, Ms. Richmond has suffered considerable damages, including, but not limited to, personal injuries, mental and emotional pain and suffering, medical expenses, and other actual damages, all in excess of Seventy-Five Thousand Dollars ($75,000.00). COUNT III – PUNITIVE DAMAGES (Both Defendants) 29. Paragraphs 1 - 28 are incorporated herein by reference. 30. The intentional, wanton, and reckless conduct of Defendants in complete disregard of Ms. Richmond and others was conducted with full knowledge, in that Defendants knew, or should have known, of the severe adverse consequences of their actions upon Ms. Richmond and others. 31. Such actions were not only detrimental to Ms. Richmond, but to the public in general. 32. Defendants acted intentionally, maliciously, and in reckless disregard of the rights of Plaintiff. As a result, Plaintiff is entitled to recover punitive damages against the Defendants. WHEREFORE, based on the foregoing, Plaintiff prays that the Court grant her the relief sought, including but not limited to actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00), punitive damages in excess of Seventy-Five Thousand Dollars ($75,000.00), all applicable pre-judgment interest, post-judgment interest, reasonable attorneys’ fees, costs, and all other relief deemed appropriate by the Court. Respectfully submitted, SMOLEN | LAW, PLLC __________________________ Donald E. Smolen, II, OBA #19944 Christopher U. Brecht, OBA #22500 611 S. Detroit Ave. Tulsa, OK 74120 P: (918) 777-4LAW (4529) F: (918) 890-4529 [email protected] [email protected] Attorneys for Plaintiff
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