IN THE DISTRICT COURT OF OKLAHOMA COUNTY
STATE OF OKLAHOMA
TYLER JAMES SANBAR, as Personal Representative of the Estate of JAMES SCOTT SANBAR, Deceased,
PLAINTIFF,
v.
UHS OKLAHOMA CITY, LLC, a Domestic Limited Liability Company, d/b/a CEDAR RIDGE BEHAVIORAL HOSPITAL AT BETHANY; UNIVERSAL HEALTH SERVICES, INC., a Delaware Corporation and UHS OF DELAWARE, INC., a Delaware Corporation, YANA JARMAN, D.O., an Individual, MEGAN HOLTE, an Individual,
DEFENDANTS.
PETITION
COMES NOW, Plaintiff, Tyler James Sanbar as Personal Representative of the Estate of James Scott Sanbar, deceased and for his cause of action against the Defendants, UHS Oklahoma City LLC, d/b/a Cedar Ridge Behavioral Hospital at Bethany, Universal Health Services Inc., UHS of Delaware Inc., Yana Jarman, D.O., an individual and Megan Holte, an individual, alleges and states as follows:
PARTIES
1. Tyler James Sanbar is the son and Personal Representative of the Estate of his father James Scott Sanbar. Tyler Sanbar is an Oklahoma citizen and resides in Cleveland County, Oklahoma.
2. UHS Oklahoma City LLC is a domestic limited liability company d/b/a Cedar Ridge Behavioral Hospital at Bethany.
3. Universal Health Services Inc. is a Delaware corporation.
4. UHS of Delaware Inc. is a Delaware corporation.
5. Yana Jarman is the Medical Director for UHS Oklahoma City, LLC, d/b/a Cedar Ridge Behavioral Hospital. Dr. Jarman is an Oklahoma citizen.
6. Megan Holte is the Director of Risk Management, Quality, and Compliance Office for UHS Oklahoma City, LLC, d/b/a Cedar Ridge Behavioral Hospital. Ms. Holte is an Oklahoma citizen.
JURISDICTION AND VENUE
7. James Scott Sanbar was a patient receiving inpatient care at Cedar Ridge Behavioral Hospital at Bethany from December 6, 2025, through December 20, 2025.
8. On December 20, 2025, James Scott Sanbar was violently assaulted by another patient at Cedar Ridge Behavioral Hospital at Bethany.
9. James Scott Sanbar required emergency hospitalization at Integris Baptist Medical Center in Oklahoma City, Oklahoma. Mr. Sanbar was in ICU at Integris Baptist Medical Center because of the severe and violent assault that occurred at Cedar Ridge Behavioral Hospital-Bethany.
10. This violent assault occurred in Oklahoma County giving rise to venue in the District Court of Oklahoma County.
11. Defendant UHS Oklahoma City, LLC, d/b/a Cedar Ridge Behavioral Hospital at Bethany ("Defendant Cedar Ridge-Bethany" or "Cedar Ridge-Bethany") is a domestic limited liability company organized and existing under the laws of the State of Oklahoma.
12. According to the records of Oklahoma Secretary of State, Cedar Ridge-Bethany's principal place of business is 367 S. Gulph Rd., King of Prussia, PA, 19406 and it conducts business at 7600 NW 23rd Street, Bethany, Oklahoma County, Oklahoma.
13. The State of Oklahoma has jurisdiction over Defendants Yana Jarman and Megan Holte because both are citizens of the State of Oklahoma and both reside in the Oklahoma City metro area.
14. Defendant Universal Health Services Inc. ("Defendant Universal Health" or "Universal Health"), is a publicly traded Delaware corporation doing business in the State of Oklahoma, thirty-eight (38) other states, Washington DC, Puerto Rico, and the United Kingdom with its principal place of business located at 367 S. Gulph Rd., King of Prussia, PA. 19406.
15. Defendant UHS of Delaware Inc. ("Defendant UHS of Delaware" or "UHS of Delaware") is a wholly owned subsidiary of Defendant Universal Health Inc., is incorporated in the State of Delaware, is registered to do business in the State of Oklahoma, and does business in the State of Oklahoma.
16. Defendant UHS of Delaware Inc.'s registered service agent in the State of Oklahoma is Corporation Service Company, 10300 Greenbriar Place, Oklahoma City, Oklahoma 73159.
17. Defendant Cedar Ridge-Bethany's registered service agent in the State of Oklahoma is Corporation Service Company, 10300 Greenbriar Place, Oklahoma City, Oklahoma 73159.
18. The State of Oklahoma has jurisdiction over Defendant Cedar Ridge-Bethany, which has its principal place of business located in Oklahoma County, Oklahoma and is the location where the violent assault occurred.
19. The State of Oklahoma has jurisdiction over Defendants Universal Health and UHS of Delaware as well. Defendants' Universal Health and UHS of Delaware own, operate, manage, and control Cedar Ridge-Bethany.
20. According to Universal Health's website, the company also has five (5) other locations in Oklahoma - Cedar Ridge Behavioral Hospital in Oklahoma County Oklahoma, St. Mary's Regional Medical Center in Garfield County Oklahoma, Thousand Branches Wellness in Oklahoma County Oklahoma, Thousand Branches Wellness in Tulsa County Oklahoma and TexomaCare Urgent Care in Bryan County Oklahoma. Including their Cedar Ridge Facility, Defendants Universal Health and UHS of Delaware own, operate, manage, and control six (6) Oklahoma facilities.
21. Defendants Universal Health and UHS of Delaware are, at all relevant times herein, doing business in the State of Oklahoma through the ownership, operation, management, marketing, promotion, and control of services provided by the six (6) aforementioned hospitals and healthcare facilities in the State of Oklahoma.
22. Defendant Universal Health and UHS of Delaware both have connections with the State of Oklahoma that are consistent with the requirements of the due process clause of the Fourteenth Amendment because each Defendant has purposely availed itself of the privilege of conducting business activities in Oklahoma by owning, operating, managing, and controlling six (6) Oklahoma facilities. The causes of action arising out of the acts and omissions that occurred in Defendants’ Cedar Ridge Facility, and each of the Defendants’ activities are so connected to Oklahoma that the exercise of jurisdiction over each Defendant is fair and reasonable.
23. The 2024 Annual Certificate that is required to be filed by the Oklahoma Secretary of State for Cedar Ridge-Bethany is signed by Steve Filton as Vice President. Mr. Filton also serves as Executive Vice President and Chief Financial Officer for Defendant Universal Health.
24. Cedar Ridge-Bethany is a wholly owned subsidiary of Universal Health.
25. UHS of Delaware is also a wholly owned subsidiary of Universal Health.
26. Upon information and belief, Universal Health and UHS of Delaware exercised sufficient control, either contractually and/or actually, over Cedar Ridge-Bethany so as to be held financially liable through the principles of either negligence, contract and/or vicarious liability, and respondeat superior under substantially similar reasoning as involved in J.M. v. Shell Oil Co., 922 S.W.2d 759 (Mo. 1996), which noted the issue is one of control and further noted a party may inadvertently and voluntarily assume responsibility and control for aspects of another’s business from which liability will arise. See Frazier v. Bryan Memorial Hospital Authority, 775 P.2d 281 (Okla. 1989), noting that the question whether an allegedly dominant corporation may be held liable for a subservient entity’s tort hinges primarily on control.
27. Universal Health is subject to this Court’s jurisdiction based on its numerous direct contacts with the State of Oklahoma, including generally its ownership, operation, management,
marketing, promotion, and control of services provided by the five (5) aforementioned hospitals and specifically the contacts of its domestic subsidiaries, Cedar Ridge-Bethany, and UHS of Delaware.
GENERAL ALLEGATIONS
28. Cedar Ridge-Bethany is a 67-bed inpatient adult psychiatric hospital located at 7600 NW 23rd Street in Bethany, Oklahoma.
29. Cedar Ridge-Bethany represents that it provides crisis stabilization and medication management to patients who have disorders such as depression, anxiety, mood disorders, paranoia, and schizophrenia.
30. Cedar Ridge-Bethany states and represents on its website that "we provide a secure haven for patients who are having suicidal or homicidal thoughts".
31. Defendant Cedar Ridge-Bethany is a specialized psychiatric hospital licensed under the law of the State of Oklahoma.
32. Defendant Universal Health owns, controls, manages, operates, and supervises Defendant Cedar Ridge-Bethany; Defendant Cedar Ridge-Bethany is the agent of Defendant Universal Health; and Defendant Universal Health is liable for the acts, omissions, and negligence of Defendant Cedar Ridge-Bethany.
33. Defendant UHS of Delaware also controls, manages, operates, and supervises Defendant Cedar Ridge-Bethany; Defendant Cedar Ridge-Bethany is the agent of Defendant UHS of Delaware; and Defendant UHS of Delaware is liable for the acts, omissions, and negligence of Defendant Cedar Ridge-Bethany.
34. Defendant Megan Holte is an employee of Defendant Cedar Ridge-Bethany and Cedar Ridge Behavioral Health. Ms. Holte is responsible for compliance and provides direction and coordination for the development and implementation of the quality improvement initiatives and plans for Cedar Ridge. She regularly reviews and develops policies to ensure consistency with facility practice
and meeting regulatory requirements. Ms. Holte is responsible for implementing policies and procedures mandated by Universal Health and/or UHS of Delaware and ensuring Defendants’ patients and residents are safe, secure, and free from violence and patient on patient assault and injury.
35. Dr. Yana Jarman, as the Medical Director for Cedar Ridge-Bethany and Cedar Ridge Behavioral Health, is responsible for assessing patients upon intake to ensure the safety of all patients that are admitted to Cedar Ridge. Dr. Jarman is responsible for implementing policies and procedures mandated by Universal Health and/or UHS of Delaware and ensuring Defendants’ patients and residents are safe, secure, and free from violence and patient on patient assault and injury.
36. As to Plaintiff’s allegations, claims and causes of action stated herein, Defendants and their agents and/or employees were acting within the scope of their employment at all times.
37. Under the doctrine of respondeat superior, Defendants are liable for the negligence and other tortious conduct of their agents and/or employees.
38. Upon information and belief, all of Defendant Cedar Ridge-Bethany’s net profits are paid to Defendant Universal Health.
39. Defendant Cedar Ridge-Bethany is required to follow Defendant Universal Health’s policies, procedures, guidelines, and rules.
40. All Defendants had a duty and responsibility to provide James Scott Sanbar with a safe patient environment, free from physical violence.
41. All Defendants had a duty and responsibility to sufficiently staff their psychiatric hospital (Cedar Ridge-Bethany) for the purpose of protecting their patients, including James Scott Sanbar.
42. All Defendants had a duty and responsibility to train their employees and/or agents in a manner that provided a safe and protective hospital environment for their patients.
43. All Defendants had a duty and responsibility to appropriately assess a patient before admitting them to Cedar Ridge Behavioral Hospital at Bethany for the purpose of ensuring patient safety.
44. All Defendants had a duty and responsibility to make sure Cedar Ridge-Bethany had enough staff on duty, at all times, to protect patients from patient-on-patient physical assault and abuse.
45. All Defendants had a duty and responsibility to make sure Cedar Ridge-Bethany had security cameras and video surveillance that allowed Defendants to monitor patients and to protect patients from patient-on-patient physical assault and abuse.
46. Defendants Universal Health and UHS of Delaware also had a duty and responsibility to make sure Cedar Ridge-Bethany had sufficient staffing for the protection of its patients.
47. Defendants Universal Health and UHS of Delaware had a duty and responsibility to ensure their policies and procedures are appropriate and followed by Cedar Ridge-Bethany.
48. At all relevant times, Defendants, and each of them, had a duty and responsibility to ensure its residents and patients at Cedar Ridge-Bethany, including Plaintiff, were safe while residing and/or undergoing treatment at the facility.
49. At all relevant times, Defendants, and each of them, had a special relationship with their patients over whom they exercised total control in their facilities.
50. That Defendants had a duty to use ordinary care to keep their premises in a reasonably safe condition for the use of James Scott Sanbar.
51. That the Defendants’ said duty or duties are nondelegable.
52. On December 20, 2025, James Scott Sanbar was violently attacked and assaulted by a fellow patient at Defendants’ Cedar Ridge-Bethany facility, which required emergency hospitalization at Integris Baptist Medical Center.
53. James Scott Sanbar died on January 20, 2026, as a direct result of the injuries inflicted on him while a patient at Cedar Ridge-Bethany.
FIRST CAUSE OF ACTION AGAINST DEFENDANTS – NEGLIGENCE AND WRONGFUL DEATH
Tyler James Sanbar as Personal Representative of the Estate of James Scott Sanbar, for his first cause of action against all Defendants, alleges and states as follows:
54. Plaintiff restates and adopts by reference the previous allegations in paragraphs 1 through 53 herein.
55. Defendants Jarman and Holte failed to ensure that the policies and procedures mandated by Universal Health and UHS of Delaware regarding the following were implemented, followed, and complied with:
a. patient assessment;
b. patient safety;
c. patient supervision; and,
d. staff training and staffing levels.
56. Defendants Jarman and Holte failed to protect their patient James Scott Sanbar from the violent attack and assault by another patient.
57. All Defendants and their agents and/or employees acted wrongfully, negligently and grossly negligent towards patient James Scott Sanbar, all of which directly led to his death. The Defendants negligence includes but is not limited to the following:
1. Failing to properly assess the Cedar Ridge-Bethany patient that violently assaulted and injured James Scott Sanbar;
2. Failing to provide for the physical safety of its patient James Scott Sanbar;
3. Failing to ensure sufficient staff were working to provide protection to its patient James Scott Sanbar;
4. Failing to train its staff, employees, and/or agents so they could provide protection for patients at Cedar Ridge-Bethany, including James Scott Sanbar;
5. Failing to monitor and supervise the patient that violently assaulted James Scott Sanbar;
6. Failing to have adequate security personnel at Cedar Ridge-Bethany to prevent violent patient-on-patient assaults;
7. Failing to follow psychiatric hospital industry standards on training and staffing for the protection of patients;
8. Failing to provide reasonable and adequate electronic monitoring for the purpose of patient safety;
9. Failing to adequately staff Cedar Ridge-Bethany and provide sufficiently trained and competent employees;
10. Failing to properly train staff, employees, and/or agents on how to prevent patient-on-patient assault and injuries;
11. Failing to adequately inform, educate or train its staff on how to identify and prevent violent patient-on-patient assaults;
12. Failing to develop and implement adequate policies and procedures to prevent violent patient-on-patient assaults;
13. Failing to adequately train staff, employees, and/or agents how to identify clear warning signs that a patient is violent and should not be allowed to interact with other non-violent patients;
14. Failing to timely discharge James Scott Sanbar; and,
15. Failing to exercise reasonable care to keep said premises in a reasonably safe condition for the use of James Scott Sanbar.
58. As a direct result of the negligence of Defendants, and each of them, Tyler James Sanbar, as Personal Representative of the Estate of James Scott Sanbar, seeks damages pursuant to Oklahoma's Wrongful Death Statute, 12 O.S. §1053. Plaintiff claims the following damages:
1. Medical and burial expenses;
2. The mental pain and anguish suffered by the decedent, James Scott Sanbar;
3. The pecuniary loss to the survivors;
4. The grief and loss of companionship of James Scott Sanbar’s son, Tyler James Sanbar;
5. The grief and loss of companionship of James Scott Sanbar’s parents, Sandy Sanbar and Dorothy Sanbar; and,
6. Punitive damages.
59. Plaintiff Tyler James Sanbar, as Personal Representative of the Estate of James Scott Sanbar claims damages in an amount in excess of Two Hundred Fifty Thousand ($250,000).
60. The conduct of the Defendants, and each of them, was in reckless disregard of James Scott Sanbar’s rights, intentional and with malice, grossly negligent, willful and wanton, and was conduct that was life threatening to James Scott Sanbar, which entitles him to punitive damages in an amount in excess of Two Hundred Fifty Thousand ($250,000).
61. Based on the conduct of the Defendants and the type and amount of damages suffered by James Scott Sanbar, this case is not subject to the Oklahoma Expedited Actions Act, Title 12, Section 1775, et seq. of the Oklahoma Statutes.
WHEREFORE, Plaintiff, Tyler James Sanbar, as Personal Representative of the Estate of James Scott Sanbar, prays for judgment in his favor, against the Defendants Cedar Ridge-Bethany, Universal Health and UHS of Delaware, Yana Jarman, D.O. and Megan Holte for actual and punitive damages in an amount in excess of Two Hundred Fifty Thousand ($250,000), for his costs expended, including a reasonable attorney’s fee; for interest at the statutory rate, and for such and further relief which this Court may deem just, equitable and proper.
Respectfully Submitted,
Joe E. White, Jr., OBA # 12930
Charles C. Weddle, III, OBA # 18869
Kate C. White, OBA # 30930
Nick W. Porter, OBA # 34176
WHITE & WEDDLE, P.C.
630 N.E. 63rd Street
Oklahoma City, OK 73105
(405) 858-8899
(405) 858-8844 Facsimile
[email protected]
[email protected]
[email protected]
[email protected]
-and-
James A. Belote, OBA # 12558
Jack Stipe, OBA # 17965
STIPE & BELOTE, LLP
9400 Broadway Extension, Suite 420
Oklahoma City, OK 73114
(405) 607-1790
(405) 607-1796 Facsimile
[email protected]
[email protected]
Attorneys for Plaintiff
JURY TRIAL DEMANDED
ATTORNEY'S LIEN CLAIMED