Tenth Circuit Preserves District Court Discretion to Exceed 30% Fee Guideline in Oklahoma Royalty Class Actions

The Tenth Circuit affirmed a $17.3 million attorneys' fee award—33.33% of a $52 million settlement fund—in an Oklahoma royalty underpayment class action, holding that district courts may exceed the 30% guideline established in Strack v. Classen where case complexity and near-complete class certification success warrant departure. The decision rejects objectors' argument that Strack imposed a hard ceiling on percentage-of-fund awards in common-fund fee applications, preserving district court discretion under Oklahoma's statutory fee factors.