Frank v. Crawley Petroleum Corp., 992 F.3d 987 (10th Cir. Mar. 29, 2021)
The plaintiffs in this putative class action filed a motion for voluntary dismissal of the complaint without prejudice. The district court granted the motion, but included a provision in the order saying that the plaintiffs’ lawyer could not file similar putative class action claims against the defendant on behalf of other plaintiffs. The lawyer challenged the order on appeal. The Tenth Circuit held the lawyer had standing to appeal because he was referenced in the order and bound by it, and that the filing restriction against the lawyer was improper because the dismissal did not cause any legal prejudice to the defendant.