BP American Production Co. v. Burton

549 U.S. 84 (2006)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

BP American Production Co. v. Burton

United States Supreme Court
549 U.S. 84 (2006)

  • Written by Brett Stavin, JD

Facts

BP American Production Co. (BP) (plaintiff) held a lease to produce gas from federal land, which required that BP pay the government a royalty equivalent to 12.5 percent of the value of gas removed or sold. For years, BP’s predecessor, Amoco Production Co. (Amoco), calculated royalties based on the value of gas when it was produced at the well, a value lower than when the gas was treated to meet certain quality standards. In 1996 the Department of the Interior’s Mineral Management Service (MMS) informed Amoco that the royalty should be based on the gas’s value once treated and ordered Amoco to pay the difference for 1989 through 1996. The assistant secretary of the interior denied Amoco’s appeal. Amoco then sought review in federal district court and the court of appeals, both of which upheld the payment order, rejecting Amoco’s argument that it was barred by the six-year statute of limitations for government-contract actions found in 28 U.S.C. § 2415(a). The Supreme Court granted certiorari. In support of its interpretation that the statute of limitations extended to administrative proceedings, BP cited precedent in which the Supreme Court held that the Clean Water Act allowed recovery of attorney’s fees for administrative proceedings, as well as precedent holding that the Equal Employment Opportunity Commission had authority to award compensatory damages in administrative proceedings. BP also cited various statutes and regulations in which the term complaint was used in the administrative-proceeding context. BP further argued that the government’s interpretation of § 2415(a) would render subsection (i) superfluous, because subsection (i) allowed federal agencies to collect claims through withholding mechanisms, and those mechanisms would be redundant if administrative proceedings were exempt from § 2415(a). Finally, BP argued that the government’s interpretation would be contrary to congressional intent and would frustrate the purpose of the statute, noting by way of example that statutory recordkeeping requirements extend back seven years, making it illogical to allow payment orders going back further in time.

Rule of Law

Issue

Holding and Reasoning (Alito, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 736,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 736,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 736,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership