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Keywords

injunctionhearingmotionleasecontinental shelf
jurisdictioninjunctionappealhearingwillleasecontinental shelf

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Amoco Production Co. v. Village of Gambell, AK, 480 U.S. 531, 107 S.Ct. 1396, 94 L.Ed.2d 542, 55 USLW 4355, 17 Envtl. L. Rep. 20,574

Facts

The Alaska Native villages of Gambell and Stebbins sought to prevent the Secretary of the Interior from proceeding with oil and gas lease sales in the Outer Continental Shelf, claiming that such actions would adversely affect their aboriginal rights to hunt and fish. They argued that the Secretary failed to comply with the Alaska National Interest Lands Conservation Act (ANILCA) § 810(a), which protects subsistence resources. The District Court denied their motion for a preliminary injunction, ruling that while the villages had a strong likelihood of success on the merits, the balance of harms did not favor them, and the public interest favored continued oil exploration.

When the Secretary of the Interior proposed Outer Continental Shelf (OCS) Lease Sale 57, the Alaska Native villages of Gambell and Stebbins sought to enjoin him from proceeding with the sale, claiming that it would adversely affect their aboriginal rights to hunt and fish on the OCS and that the Secretary had failed to comply with ANILCA § 810(a), 16 U.S.C. § 3120(a), which provides protection for natural resources used for subsistence in Alaska.

Issue

Did the Alaska National Interest Lands Conservation Act § 810(a) apply to the Outer Continental Shelf, and were the villages entitled to a preliminary injunction against the Secretary's lease sales?

Did the Alaska National Interest Lands Conservation Act § 810(a) apply to the Outer Continental Shelf, and were the villages entitled to a preliminary injunction against the Secretary's lease sales?

Rule

The Alaska National Interest Lands Conservation Act § 810(a) requires federal agencies to consider the impact of actions on subsistence resources and to provide notice and conduct hearings before allowing actions that would significantly restrict subsistence uses. However, the Act's provisions apply only to federal lands within the State of Alaska and do not extend to the Outer Continental Shelf.

Section 810(a) of the Alaska National Interest Lands Conservation Act (ANILCA) provides, inter alia, that, before allowing the use, occupancy, or disposition of public lands that would significantly restrict Alaskan Natives' use of those lands for subsistence, the head of the federal agency having primary jurisdiction over the lands must give notice, conduct a hearing, and determine that the restriction of subsistence uses is necessary and that reasonable steps will be taken to minimize adverse impacts.

Analysis

The Supreme Court found that the Ninth Circuit erred in directing a preliminary injunction, emphasizing that the purpose of ANILCA § 810 is to protect subsistence resources from unnecessary destruction, not to prohibit all federal land uses that may adversely affect such resources. The Court noted that the District Court's findings indicated that exploration activities would not significantly restrict subsistence uses, and the Secretary retained control over the offshore leasing process. The Court also rejected the presumption of irreparable harm established by the Ninth Circuit, stating it was contrary to traditional equitable principles.

The Court of Appeals' direction of a preliminary injunction conflicted with Weinberger v. Romero-Barcelo, 456 U.S. 305, 102 S.Ct. 1798, 72 L.Ed.2d 91, and was in error. Section 810(a)'s purpose is to protect subsistence resources from unnecessary destruction, not to prohibit all federal land uses that would adversely affect such resources, and there is no clear indication in ANILCA that Congress intended to limit district courts' traditional equitable discretion by requiring them to issue injunctions in all cases.

Conclusion

The Supreme Court reversed the Ninth Circuit's direction for a preliminary injunction and held that ANILCA § 810(a) does not apply to the Outer Continental Shelf, thus vacating and remanding the case.

Accordingly, the Ninth Circuit erred in directing the issuance of a preliminary injunction.

Who won?

The Secretary of the Interior prevailed in the case because the Supreme Court found that the Alaska National Interest Lands Conservation Act did not apply to the Outer Continental Shelf and that the villages were not entitled to a preliminary injunction.

The Secretary of the Interior prevailed in the case because the Supreme Court found that the Alaska National Interest Lands Conservation Act did not apply to the Outer Continental Shelf and that the villages were not entitled to a preliminary injunction.

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