Impact Energy Resources, LLC v. Salazar
United States District Court for the District of Utah
2010 WL 3489544 (2010)
- Written by Robert Cane, JD
Facts
The United States Department of the Interior, Bureau of Land Management (bureau) (defendant) administered oil-and-gas lease sales pursuant to the Mineral Leasing Act. The bureau conducted a lease sale of parcels in Utah. The lease sale faced numerous protests because of the proximity to two national parks and other sensitive and unique land. Ultimately, the bureau proceeded with the lease sale and accepted bids for the lease parcels. After the lease sale, Ken Salazar (defendant) was appointed the new secretary of the United States Department of the Interior. Secretary Salazar issued a memorandum that directed the bureau to withdraw the leases. Impact Energy Resources, LLC (Impact) (plaintiff), one of the winning bidders during the lease sale, appealed the withdrawal of the leases to the Interior Board of Land Appeals (board). Impact was a responsible qualified bidder and had made the highest bid, which met the national minimum-acceptable bid. The board found that the secretary had broad discretion to withdraw lease sales until the actual issuance of a lease. Impact appealed the board’s decision to the district court, arguing that the secretary was mandated to issue a lease after offering it for sale and receiving an acceptable bid.
Rule of Law
Issue
Holding and Reasoning (Benson, J.)
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