Seeco, Inc., Appellant v. Eldridge Snow, Appellees

Summary

The court affirmed certification of a class of Arkansas citizens who owned royalty interests under specified Fayetteville Shale leases, concluding that the circuit court acted within its discretion in finding the Rule 23 requirements satisfied. The class was sufficiently defined, the common question whether SEECO's uniform post-production charge was unreasonable predominated over individual issues, and the representative's adequacy, typicality, and the superiority of class treatment were adequately shown. The court did not reach SEECO's due-process challenge because SEECO had not obtained a ruling on it below. Justice Wood, concurring, agreed with affirmance but would have rejected the citizenship-based class definition as potentially unmanageable and likely subject to later decertification.