Udall v. Tallman
380 U.S. 1 (1965)
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Rule of Law:
When reviewing an administrative agency's interpretation of its own regulations or the executive orders it administers, courts must give controlling weight to that interpretation unless it is plainly erroneous or inconsistent with the regulation. This deference is particularly strong when the interpretation is long-standing and has been relied upon by the public.
Facts:
- In 1941, President Roosevelt issued Executive Order No. 8979, creating the Kenai National Moose Range in Alaska and stating the lands were not subject to 'settlement, location, sale, or entry, or other disposition.'
- In 1948, the Secretary of the Interior issued Public Land Order No. 487, which similarly withdrew adjacent lands from 'settlement, location, sale or entry.'
- The Department of the Interior consistently interpreted these orders as not prohibiting oil and gas leasing on the withdrawn lands.
- Between October 1954 and January 1955, D. J. Griffin and others (the Griffin lessees) filed applications for oil and gas leases on lands within the Kenai Range.
- In reliance on the Secretary's interpretation, oil and gas exploration and development occurred in the Range, including the discovery of commercial quantities of oil in July 1957.
- On August 14, 1958, following a clarification of departmental regulations, respondents (Tallman et al.) filed offers to lease the same lands for which the Griffin lessees had previously applied.
- Effective September 1, 1958, the Department of the Interior issued the leases to the Griffin lessees, having determined they were the first qualified applicants.
Procedural Posture:
- Respondents' applications for oil and gas leases were rejected by the Bureau of Land Management in October 1959 on the grounds that the lands had already been leased to prior applicants (the Griffin lessees).
- Respondents appealed to the Director of the Bureau of Land Management, who affirmed the rejection.
- Respondents then appealed to the Secretary of the Interior, who also affirmed the decision.
- Respondents filed an action in the nature of mandamus in the United States District Court for the District of Columbia to compel the Secretary to issue leases to them.
- The District Court granted summary judgment in favor of the Secretary.
- Respondents, as appellants, appealed to the U.S. Court of Appeals for the District of Columbia Circuit, which reversed the District Court's judgment.
- The Secretary of the Interior, as petitioner, sought and was granted a writ of certiorari from the U.S. Supreme Court.
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Issue:
Do Executive Order No. 8979 and Public Land Order No. 487, which withdrew certain public lands from 'settlement, location, sale, or entry, or other disposition,' thereby withdraw those lands from oil and gas leasing under the Mineral Leasing Act?
Opinions:
Majority - Mr. Chief Justice Warren
No. The executive and public land orders did not withdraw the lands in question from oil and gas leasing. When a court construes an administrative regulation, the agency's interpretation is of controlling weight unless it is plainly erroneous or inconsistent with the regulation. Here, the Secretary of the Interior has consistently interpreted the orders to permit oil and gas leasing, a construction that has been a matter of public record and upon which private parties have relied to their great expense. The Secretary's interpretation is reasonable because the terms 'settlement,' 'location,' 'sale,' and 'entry' all contemplate a transfer of title, and the general term 'other disposition' can reasonably be read to include only similar actions, which a lease is not. Furthermore, the term 'public-land laws' used in the order is often distinguished in legal parlance from 'mineral-leasing laws,' supporting the conclusion that the latter were not covered by the withdrawal.
Analysis:
This case is a foundational administrative law decision establishing the principle of strong judicial deference to an agency's interpretation of its own ambiguous regulations, a doctrine often referred to as 'Seminole Rock' or 'Auer' deference. The ruling solidifies the idea that administrative expertise and consistency are paramount, and that courts should not substitute their own judgment for a reasonable, long-standing agency interpretation. This precedent provides stability and predictability for individuals and industries that rely on agency guidance and protects significant investments made in reliance on such interpretations.
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