Rider, et al. v. Oxy USA, et al.
Split Score
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Case Summary
Disposition
Reversed
The Tenth Circuit reversed the district court’s denial of class certification in a royalty-underpayment suit arising out of a 2008 settlement between Kansas royalty owners and OXY USA. Applying its newly announced Cline v. Sunoco standard, the court held that Rule 23 does not require an "administrative feasibility" showing for ascertainability and directed the district court to certify the proposed class on remand.
Circuit Split Identified
Legal Issue
Whether Rule 23’s implicit ascertainability requirement includes a separate "administrative feasibility" component that obligates the proponent of class certification to show an administratively workable method of identifying class members.
Circuit Positions
Ascertainability requires a reliable, administratively feasible mechanism for identifying each class member in addition to a clear, objective definition.
Ascertainability only requires a clear, objective class definition; no separate administrative-feasibility showing is necessary.
Conflict Summary
The Third Circuit requires both an objective class definition and proof of a reliable, administratively feasible mechanism for identifying class members, while the Seventh Circuit—and now the Tenth Circuit—hold that ascertainability is satisfied so long as the class is defined by clear, objective criteria, rejecting any additional administrative-feasibility prerequisite.