Amoco Production Company v. Southern Ute Indian Tribe
United States Supreme Court
526 U.S. 865 (1999)
- Written by Colette Routel, JD
Facts
In 1880, the Southern Ute Indian Tribe (tribe) (plaintiff) ceded a portion of its reservation lands to the United States. Some 200,000 acres of this land were later granted in fee simple to homesteaders under the Coal Lands Acts of 1909 and 1910 (coal acts), but the United States reserved for itself “all coal in said lands.” In 1938, the United States returned the coal interests it had retained to the tribe. When the coal acts were passed, coalbed methane was a dangerous waste product that escaped from coal when it was mined. Decades later, coalbed methane was a profitable commodity. Some landowners executed oil-and-gas leases with Amoco Production Company (Amoco) (defendant) to allow Amoco to extract the coalbed methane from underneath their lands. The tribe sued Amoco, seeking a declaration that coalbed methane could be extracted only by the holder of the coal rights, not by the landowner or his lessee. The district court disagreed with the tribe and concluded that coal was a “solid rock substance” that did not include coalbed methane gas. The tribe appealed, and the United States Court of Appeals for the Tenth Circuit, sitting en banc, reversed. Amoco then petitioned the Supreme Court, which granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
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