Black, et al. v. Occidental Petroleum, et al., No. 22-8040 (10th Cir. 2023)Annotate this Case
Plaintiffs-landowners alleged Anadarko Petroleum Corporation's intracompany practice of leasing its mineral interests to its affiliated operating company, including its 30% royalty rate, had the intent and effect of reducing the value of Plaintiffs’ mineral interests. Plaintiffs claimed Anadarko thereby maintained and furthered its dominant position in the market for leasing oil and gas mineral interests in violation of the Sherman Act § 2 and Wyoming antitrust laws. Plaintiffs sought treble damages and attorneys’ fees under § 4 of the Clayton Act. The federal district court certified a class action, for liability purposes only, comprised of “[a]ll persons . . . having ownership of Class Minerals during the Class Period.” Anadarko appealed the district court’s class certification pursuant to Federal Rule of Civil Procedure 23(f). The Tenth Circuit concluded the district court applied the correct legal standard in deciding whether the class satisfied the requirements of Rule 23, and it did not abuse its discretion in certifying the class. The Court therefore affirmed the district court’s class certification.