Phillips Petroleum Co. v. Shutts
United States Supreme Court
472 U.S. 797 (1985)
Royalty owner Shutts (plaintiff) brought a nationwide class action in Kansas against Phillips Petroleum (defendant) over delayed royalty interest payments on gas leases in 11 states; Kansas certified a class of over 28,000 members, roughly 97% of whom had no connection to Kansas beyond the suit, after mailing notice letting members opt out. The Kansas courts applied Kansas law to every class member's claim and found Phillips liable for interest on delayed payments; Phillips challenged both the court's jurisdiction over out-of-state absent class members and the blanket application of Kansas law, and the U.S. Supreme Court granted review.
Whether a state may exercise jurisdiction over an absent class-action plaintiff who lacks minimum contacts with the state so long as minimal procedural due process is provided, and whether the forum state must have a significant contact or aggregation of contacts with each class member's claim before applying its own law to that claim.