From our private database of 33,800+ case briefs...
National Wildlife Federation v. Burford
United States Court of Appeals for the Ninth Circuit
871 F.2d 849 (1989)
Section 201(a)(1) of the Mineral Leasing Act of 1920, 30 U.S.C. §§ 181 et seq., required coal-lease bids to be at least fair market value, as determined by the secretary of the interior (secretary). Section 201(a)(1) also required the secretary to use competitive bidding to award leases. An interpretive regulation, 43 C.F.R. § 3400.0-5(n), defined “fair market value” as the cash amount, or cash equivalent, for which a knowledgeable buyer would sell or lease coal to a knowledgeable purchaser. The secretary replaced the prior minimum-acceptable-bid (MAB) system with an entry-level-bid (ELB) system, based on studies suggesting a decline in the western coal market. The secretary subsequently accepted coal-lease bids for the Powder River Basin (Basin) area using the ELB system. Pre-sale estimates were based on a prior coal-lease sale that was not comparable to the Basin sale. However, an economic evaluation committee concluded that the prior sale was best suited to the type of lease available in the Basin. The National Wildlife Federation and other environmental groups (plaintiffs) sued BLM Director Robert Burford, the secretary, and others (defendants) in federal district court, challenging the secretary’s use of the ELB system. The district court found that the secretary had acted reasonably in accepting the bids, and entered summary judgment in favor of the defendants. The plaintiffs appealed, arguing that (1) the ELB system was deficient because it provided less than fair market value, (2) the shift to the ELB system was irrational and insufficiently explained in the record, (3) pre-sale estimates did not represent fair market value because they were based on a prior coal-lease sale that was not comparable to the Basin sale, and (4) the bidding process was corrupted by procedural irregularities that included price leaks to industry representatives.
Rule of Law
Holding and Reasoning (Hug, J.)
What to do next…
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 606,000 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
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 606,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 33,800 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.