Tenth Circuit: Operator Payment Records Satisfy Administrative Feasibility for Royalty Class Certification Without Title Searches

The Tenth Circuit reversed denial of class certification in a Hugoton Gas Field royalty dispute, holding that Merit Energy's business records identifying 1,900+ royalty payees satisfied administrative feasibility without requiring individualized title searches for each claimant. The court rejected OXY's argument that proof of record title ownership was necessary at the certification stage when the operator maintains payment records tied to a 2008 settlement agreement capping gathering charges at $0.15/mmbtu.