Phillips Petroleu v Shults

1985

Venue: SCOTUS

Facts: Phillips leases land from others to collect gas. The landowners get some royalties, based on the price of gas. But that price fluctuates, and maybe Phillips strategically plans payments to its advantage or something.

Posture: Suit on behalf of 33,000 small royalty owners (average payment is $100) in KS state court. Class is certified. Phillips loses. Appeal as to jurisdiction, since service was by mail with an opt-out checkbox, and only 0.0025% of the leases involved were on KS land.

Issue: Two of them:
  1. Was the procedure here sufficient to bind non-KS class members?
  2. Can the courts apply KS law to all the claims?

Holding: Yes and yes. Affirmed.

Rule: A lengthy statement of notice requirements.

Reasoning: The interests of defendants (paticularly those from elsewhere) are way greater than those of absentee plaintiffs. So you get due process, but not as much of it.

Dicta: