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Quantum Exploration, Inc. v. Clark

780 F.2d 1457 (1986)

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Quantum Exploration, Inc. v. Clark

United States Court of Appeals for the Ninth Circuit
780 F.2d 1457 (1986)

Facts

The Indian Mineral Development Act of 1982 (IMDA) enabled Native American tribes to enter contractual agreements for joint ventures with mineral developers, subject to approval by the Secretary of the Interior (defendant). The Blackfeet Tribal Business Council (the council) approved such an agreement with Quantum Exploration, Inc. (Quantum) (plaintiff) for oil-and-gas exploration on Blackfeet lands. The agreement was submitted to the Interior Secretary for the required approval. However, before the Interior Secretary could grant approval or disapproval, the tribe was advised by the Bureau of Indian Affairs (BIA), an agency of the Interior Department, that the agreement was not in the tribe’s best interests. The council then decided to rescind the agreement. Quantum brought suit against the Interior Secretary in federal district court, alleging that the failure to approve or disapprove constituted a violation of the IMDA. Quantum also alleged that the BIA’s consultation with the tribe was an IMDA violation because it interfered with Quantum’s contractual relations with the council. The court dismissed the suit, holding that Quantum lacked standing. Quantum appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Brunetti, J.)

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