State of Louisiana Ex Rel. William J. Guste, Jr., Attorney General, Plaintiff- and Cashco Oil Co., Intervenors-Appellants v. United States of America

832 F.2d 935
CourtCourt of Appeals for the Fifth Circuit
DecidedDecember 23, 1987
Docket87-4106
StatusPublished
Cited by16 cases

This text of 832 F.2d 935 (State of Louisiana Ex Rel. William J. Guste, Jr., Attorney General, Plaintiff- and Cashco Oil Co., Intervenors-Appellants v. United States of America) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana Ex Rel. William J. Guste, Jr., Attorney General, Plaintiff- and Cashco Oil Co., Intervenors-Appellants v. United States of America, 832 F.2d 935 (5th Cir. 1987).

Opinion

REAYLEY, Circuit Judge:

Louisiana sued the United States and a federal lessee operating on the Outer Continental Shelf for violations of the Outer Continental Shelf Lands Act, 43 U.S.C. § 1331 et seq. (1986), and an alleged policy agreement between Louisiana and the United States. The district court entered summary judgment for the United States and its lessee, 656 F.Supp. 1310. We affirm.

Pursuant to a federal lease, the Samedan Oil Corporation (“Samedan”) conducts an offshore drilling operation on federal Outer Continental Shelf (“OCS”) territory which borders the Louisiana offshore boundary. The leased federal tract is adjacent to state tracts leased by the Cashco Oil Company, the Seneca Resources Corporation and the Pelto Oil Company (collectively referred to as the “state lessees”).

The State of Louisiana sued the United States, the Secretary of the Interior (the “Secretary”), the Director of the Minerals Management Service (“MMS”) (collectively referred to as the “federal defendants”) and Samedan seeking declaratory and in-junctive relief in connection with Same-dan’s “imprudent and wasteful spacing, drilling, completion, and production practices” on its federal lease. Louisiana asserted that a common reservoir of natural gas underlay the federal/Louisiana border with 84% of the reserves located on Louisiana territory and 16% on the federal domain and that Samedan was draining state reserves and engaging in wasteful practices with the permission of the federal defendants.

The state raised three causes of action. First, it alleged that the federal defendants have a duty under 43 U.S.C. § 1337(g) (1986) to enter into a unitization agreement 1 with the Governor of Louisiana and sought a temporary restraining order and preliminary and permanent injunctions limiting Samedan’s production. It also sought preliminary and permanent injunctions directing the Secretary to engage in negotiations to achieve unitization with respect to Samedan’s lease and a declaratory judgment holding that the Secretary’s refusal to unitize violates § 1337(g).

Second, it alleged that the MMS is in violation of a 1975 policy agreement between Louisiana and the MMS and that the MMS is permitting Samedan to operate in violation of this agreement. Louisiana sought the same relief requested in its first cause of action with the exception of the desired declaratory judgment, which differed in that it sought a holding that the MMS was in violation of the policy agreement.

Louisiana’s third contention was that Samedan is violating Louisiana’s correlative rights by engaging in wasteful production practices and that the federal defendants are in violation of the Outer Continental Shelf Lands Act (“OCSLA”), 43 U.S.C. § 1331 et seq., by permitting these practices. It sought a temporary restraining order and preliminary and permanent injunctions limiting Samedan’s production to prevent waste.

The district court granted the state lessees’ motion to intervene as plaintiffs and the state lessees adopted the causes of action and relief sought by Louisiana. The court denied Louisiana’s motion for a preliminary injunction limiting Samedan’s production. The federal defendants and Same-dan separately moved for summary judgment and the federal defendants moved to *938 dismiss the section 1337(g) unitization claim under Fed.R.Civ.P. 12(b)(2). The court granted the motions for summary judgment as to all three causes of action and, after relabeling the 12(b)(2) motion to a motion under 12(b)(6), granted that motion as well. 2 This appeal is taken by Louisiana and the state lessees.

We hold that the Secretary has no duty to unitize under section 1337(g)(3) as amended, that the alleged policy agreement did not create legally enforceable rights and that no evidence is presented that Sam-edan engaged in wasteful practices. We therefore affirm the judgment below.

1. Unitization Under Section 1337(g) as Amended in 1986

Louisiana contends that section 8(g) of the OCSLA, 43 U.S.C. § 1337(g), as amended in 1986, requires the Secretary to engage in good faith negotiations with the Governor of Louisiana to achieve unitization of the federal and state tracts upon which Samedan and the state lessees operate. A brief review of the history of section 8(g) is in order.

In 1953, the Submerged Land Act, 43 U.S.C. § 1301 et seq., was passed giving coastal states the right and power to manage submerged lands adjoining their respective coasts. For most coastal states, including Louisiana, the grant extends seaward for three miles. The enactment of the OCSLA in 1953, 43 U.S.C. § 1331 et seq., authorized the Secretary of the Interior to issue oil, gas and other mineral leases for the submerged lands of the continental shelf, which begins where the states’ jurisdiction ends.

While these statutes established jurisdictional boundaries, they did not address the issue of drainage. Because oil and gas reserves can straddle the jurisdictional boundary, it is possible for the lessee of one government to drain the reserves located on the other government’s territory. Under the common law rule of capture, which we apply to the OCS, 3 the owner of land has the right to capture oil and gas underlying his property, including that which migrates to his property from another’s land.

In 1978, Congress amended the OCSLA, adding a new section 8(g), 43 U.S.C. 1337(g), 4 which specifically addressed the *939 administration of federal OCS lands situated between three and six miles offshore (the “8(g) zone”). Section 8(g) essentially established a scheme whereby revenues obtained by a federal lessee operating in the 8(g) zone would be shared in a fair and equitable manner by the federal government and the coastal state if a determination was made that a common field of oil or gas underlay federal and state territory so as to create a threat of drainage by the federal lessee. 5

Section 8(g)(1) required that the Secretary provide certain information to the Governor of the affected coastal state at the time that nominations were solicited for the leasing of lands in the 8(g) zone.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State of Louisiana v. Salazar
170 F. Supp. 3d 75 (District of Columbia, 2016)
Tyler v. Smith
472 F. Supp. 2d 818 (M.D. Louisiana, 2006)
Meadows v. Odom
356 F. Supp. 2d 639 (M.D. Louisiana, 2005)
Wright v. United States Postal Services
344 F. Supp. 2d 956 (M.D. Louisiana, 2004)
Cinel v. Connick
Fifth Circuit, 1996
Alabama v. United States Department of the Interior
84 F.3d 410 (Eleventh Circuit, 1996)
Resolution Trust Corp. v. Scott
887 F. Supp. 937 (S.D. Mississippi, 1995)
Provident Mutual Life Insurance v. City of Atlanta
864 F. Supp. 1274 (N.D. Georgia, 1994)
United States v. Randall K. Wood
925 F.2d 1580 (Seventh Circuit, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
832 F.2d 935, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-ex-rel-william-j-guste-jr-attorney-general-ca5-1987.