Marathon Oil Co. v. Federal Energy Administration

547 F.2d 1140, 1976 U.S. App. LEXIS 5977
CourtTemporary Emergency Court of Appeals
DecidedDecember 6, 1976
DocketNo. 6-11
StatusPublished
Cited by16 cases

This text of 547 F.2d 1140 (Marathon Oil Co. v. Federal Energy Administration) is published on Counsel Stack Legal Research, covering Temporary Emergency Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marathon Oil Co. v. Federal Energy Administration, 547 F.2d 1140, 1976 U.S. App. LEXIS 5977 (tecoa 1976).

Opinion

CHRISTENSEN, Judge.

This case presents the question of whether, absent express authority in the Emergency Petroleum Allocation Act for the regulation of credit terms as such, the Federal Energy Office, now the Federal Energy [1141]*1141Administration (FEA),1 was precluded from requiring a continuation of normal credit practices by suppliers of petroleum products as a part of its “maintenance of normal business practices rule.”

In the light of Shell Oil Co. v. FEA, 527 F.2d 1243 (Em.App.1975), and Atlantic Richfield Co. v. Zarb, 532 F.2d 1363 (Em. App.1976), which the court below interpreted as requiring the striking down of the credit terms “regulation”, we must reexamine the breadth and flexibility of the agency’s powers in accomplishing the objectives of the Act and the administrative deference rule which, with other considerations, led us in Condor Operating Company v. Sawhill, 514 F.2d 351 (Em.App.), cert. denied, 421 U.S. 976, 95 S.Ct. 1975, 44 L.Ed.2d 467 (1975), to sustain as neither arbitrary, capricious nor beyond statutory authority the FEA’s supplier/purchaser relationship maintenance rule concerning the sale of domestic crude oil.

Plaintiff-appellee, Marathon Oil Company, filed this action in the district court to enjoin the enforcement of provisions of the FEA’s regulations dealing with rentals of real property used in the retailing of gasoline,2 and credit terms under which its products were sold.3 The rental regulations were held invalid in Shell Oil, supra, and that ruling is not disputed in this case.

Marathon further contended successfully before the district court, and its position remains the same here, that the FEA lacked authority under § 4(a) of the Emergency Petroleum Allocation Act, 15 U.S.C. § 753(a) (Supp. V, 1975), to require the maintenance of normal credit terms in petroleum product transactions as a part of its mandatory allocation and pricing program. Because power to regulate credit terms was expressly granted in the now expired Economic Stabilization Act4 but not explicitly continued by the EPAA,5 Congress must have intended, Marathon argued, to withhold from the President any authority to control credit terms in connection with sales of petroleum products. Marathon additionally asserted that the maintenance of seasonal credit terms and payment schedules in “summer fill” and other “dating” programs [1142]*1142under 10 C.F.R. § 210.62(a) was not consistent with provisions in § 4(b)(2) of the EPAA requiring provision, among other things, for a dollar-for-dollar passthrough of net increases in the cost of crude oil, residual fuel oil and refined petroleum products, and use of the same date in the computation of markup, margin and posted price for such products.

The latter contention was not reached by the district court in view of its agreement with Marathon’s major contention that there was an overriding absence of authority for the agency to “regulate” credit terms at all. On cross-motions for summary judgment, it concluded that “10 C.F.R. § 210.-62(a) [see n. 3] is invalid as beyond the scope of authority granted by the Emergency Petroleum Allocation Act ... to the extent that it regulates the credit terms which a supplier of petroleum products may apply to the purchaser of said products.” Accordingly, the court granted plaintiff’s (appellee’s) motion for summary judgment and denied defendants’ (appellants’) motion.

Conceding that “the government’s reasoning with respect to the necessity for regulating credit is much more cogent than it is with respect to rents”, the district court found itself unable to “circumvent the fact that no authority was granted under the Allocation Act to regulate credit.”6 Principally on this theory, it concluded that Shell Oil and Atlantic Richfield, supra, mandated invalidation of the regulation in question, and it added:

The Government relies heavily upon the legislative history of the Allocation Act, and while it is clear from said history that Congress intended to continue the price controls established by Phase IV under the Stabilization Act, Consumers Union of the United States v. Sawhill, 525 F.2d 1068 ([Em.App.] 1975), it is not at all clear that credit terms were being regulated under Phase IV. In fact, the opposite is true. Interest rates and finance charges were not subject to regulation under Phase IV. See Cost of Living Council Freeze Regulations, Special Freeze Questions and Answers No. 8, Question 12, 38 Fed.Reg. 17491 (July 2, 1973); Cost of Living Council Ruling 1972-73, 37 Fed.Reg. 197491 (July 6, 1972). Thus even though Congress intended the Phase IV price controls to continue, this did not include the regulation of credit terms. This Court is therefore compelled to find' that, as with rental regulations, the regulation of credit terms is beyond the scope of the authority granted in the Allocation Act.

We granted the government’s motion for stay pending appeal and denied Marathon’s motion to dismiss the appeal or in the alternative to affirm, in the tentative view that the appeal could not be considered frivolous and, particularly, that Shell Oil and Atlantic Richfield did not as a matter of law foreclose the government’s position. Thus, we maintained the status quo pending more thorough consideration following briefing and oral argument.

In Shell Oil this court determined that the FEA at the time in question had no power to regulate rentals of service station property either from any independent authorization or as a part of its authority to regulate oil allocations and pricing under the EPAA. The problem here presented, however, for reasons which follow, is not analogous to those we confronted in Shell Oil, and Atlantic Richfield, accepting each of the grounds of decision there as correctly determined.7

[1143]*1143In both cases, there was involved a regulation of the operation of service stations, per se,8 as distinguished from the provision here in question tied closely to the maintenance of normal business practices in relation to pricing of products.9 In turn, the latter aspect of the regulation is more clearly allied with the continuation of the relationship device basic to the allocation program as a whole.10

A little history will render other distinctions plainer and establish that while the trial court would have been accurate if it had observed that credit terms were not regulated throughout the entire economy under Phase IV, it erred in assuming that credit terms in connection with the sale of petroleum products had not been.

The Economic Stabilization Act of 1970, as amended 12 U.S.C.

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Bluebook (online)
547 F.2d 1140, 1976 U.S. App. LEXIS 5977, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marathon-oil-co-v-federal-energy-administration-tecoa-1976.