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Secretary of the Department of the Interior v. California
United States Supreme Court
464 U.S. 312 (1984)
The United States Department of the Interior (Interior) (defendant) began preparing a sale of outer continental shelf (OCS) leases (Lease Sale 53) in 1977. After Interior sought input from several state and federal agencies, it requested that any interested parties identify exactly which of the 2,036 potential tracts in the subject area should be offered for lease. Interior selected 243 tracts. The California Coastal Commission (CCC) had authority over the coastal zone (the area three miles seaward from the coastline). The CCC determined that Lease Sale 53 directly affected the California coastal zone. The CCC informed Interior of its determination and demanded a consistency determination as required by § 307(c)(1) of the Coastal Zone Management Act (CZMA) for activities directly affecting coastal zones. Interior refuted the CCC’s determination that the lease sales directly affected the coastal zone, but it removed 128 of the selected tracts. Later, the CCC asserted that 31 more tracts should be removed from the lease sale due to proximity to the range of the sea otter. Interior rejected the CCC’s demands and issued a final notice of sale for the remaining 115 tracts. The State of California (plaintiff) filed two suits in federal district court. California sought to enjoin the sale of 29 tracts located within 12 miles of the sea-otter range based on a violation of § 307(c)(1), arguing that the leasing would lead to oil-and-gas development, which would directly affect the coastal zone. California moved for summary judgment, which the district court granted on the state’s CZMA claim. Interior appealed. The court of appeals affirmed the district court’s judgment that required a consistency determination prior to sale. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (O’Connor, J.)
Dissent (Stevens, J.)
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