Frank v. Crawley Petroleum Corp., No. 20-6018 (10th Cir. 2021)
Annotate this CaseRex Sharp, the attorney for Plaintiff Duncan Frank in a putative class-action against Crawley Petroleum Corporation, appealed a district-court order granting Plaintiff’s motion for voluntary dismissal of his claim with prejudice but placing three restrictions on Sharp’s bringing similar putative class-action claims against Crawley on behalf of other plaintiffs. Plaintiff owned a royalty interest in an oil and gas well operated by Crawley in Oklahoma. He alleged that Crawley had been underpaying the royalties owed on natural-gas production. Sharp claimed two of the three conditions were improperly imposed because the dismissal caused no legal prejudice to Crawley. Crawley moved to dismiss the appeal for lack of jurisdiction. The Tenth Circuit denied the motion to dismiss because Sharp was expressly referenced in the order and was directly bound by it. And although a nonparty, he was a proper appellant, he had standing to appeal, and the order was a final, appealable order. The Tenth Circuit also agreed with Sharp on the merits of his appeal: Crawley would not be better off in regard to class certification than it was with the dismissal with prejudice of Plaintiff’s complaint. The matter was remanded to the district court with instructions to grant Plaintiff’s requested dismissal without the challenged conditions.
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