Successful Defense of Class Action Royalty Dispute

SHR sued Shell Oil Co. subsidiary as a purported class representative to challenge Shell's calculation of royalties on gas produced from well in Michigan. Shell moved for dismissal on the basis res judicata because SHR had been a member of an earlier class action against Shell in which other aspects of royalty calculation had been litigated to settlement and judgment. Court held that the current claim was barred by judgment in the earlier class action and dismissed SHR's claims because they could have been raised in the prior class action.