Amoco Production v. Village of Gambell
Annotate this Case
480 U.S. 531 (1987)
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U.S. Supreme Court
Amoco Production v. Village of Gambell, 480 U.S. 531 (1987)
Amoco Production Co. v. Village of Gambell
Argued January 12, 1987
Decided March 24, 1987
480 U.S. 531
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. Petitioner Secretary of the Interior (Secretary) granted oil and gas leases to petitioner oil companies off the Alaska coast under the Outer Continental Shelf Lands Act (OCSLA). Claiming that the Secretary had failed to comply with § 810(a), respondents, two Alaska Native villages and a Native organization, sought injunctions to, inter alia, prohibit exploratory drilling under the leases. The District Court held that ANILCA applies to the OCS. It denied respondents' motions for preliminary injunctions, ruling that, although respondents had established a strong likelihood of success on the merits, injunctive relief was inappropriate because the balance of irreparable harm did not favor them, and the public interest favored continued oil exploration, which would not cause the type of harm -- a restriction in subsistence uses or resources -- that ANILCA was designed to prevent. The Court of Appeals affirmed the holding that ANILCA applies to the OCS, but reversed the District Court's denial of a preliminary injunction. The court held, inter alia, that irreparable damage is presumed when an agency fails to evaluate thoroughly the environmental impact of a proposed action, and that injunctive relief is the appropriate remedy for a violation of an environmental statute, absent rare or unusual circumstances.
1. The Court of Appeals' direction of a preliminary injunction conflicted with Weinberger v. Romero-Barcelo, 456 U. S. 305, 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. The Court of Appeals erroneously focused on § 810's procedure, rather than on its underlying substantive policy of preservation of subsistence resources. The District Court's decision does not undermine that policy, since it was based on findings that exploration activities would not significantly restrict subsistence uses, and that the Secretary can control the offshore leasing process even after exploration is completed, which findings the Court of Appeals did not dispute. Instead, that court stated and relied on a presumption of irreparable harm which is contrary to traditional equitable principles, has no basis in ANILCA, and is unnecessary to fully protect the environment. Furthermore, the balance of harms favors the District Court's ruling, since the oil company petitioners had committed approximately $70 million to exploration which would have been lost had the preliminary injunction been issued. Moreover, the Court of Appeals' conclusion that the public interest favored injunctive relief because the interests served by ANILCA supersede all others is not supported by the statutory language, which merely declares that preservation of subsistence resources is a public interest that should be reconciled with competing interests where possible. Pp. 480 U. S. 541-546.
2. Section 810(a) does not apply to the OCS. Pp. 480 U. S. 546-555.
(a) By ANILCA's plain language, § 810(a) applies only to federal lands within the State of Alaska's boundaries, since the Act defines "public lands" to mean federal lands situated "in Alaska," which phrase has a precise geographic/political meaning that can be delineated with exactitude to include coastal waters to a point three miles from the coastline, where the OCS commences. Pp. 480 U. S. 546-548.
(b) Nothing in the language or structure of ANILCA compels this Court to deviate from the plain meaning of "Alaska." Title VIII's subsistence protection provisions constitute just 1 of ANILCA's 15 Titles, none of the rest of which has any express or implied applicability to the OCS, and all but 2 of which utilize the same definition of "public lands" as Title VIII. Moreover, § 1001(a) of the Act contains the lone express reference to the OCS which is intended to establish that section's inapplicability to the OCS. Furthermore, § 810(a) itself suggests that it does not apply to the OCS when it refers to "the Federal agency having primary jurisdiction," since no federal agency has "primary jurisdiction" over the OCS. Pp. 480 U. S. 548-552.
(c) The similarity between ANILCA's language and that of its two statutory predecessors, the Alaska Statehood Act and the Alaska Native Claims Settlement Act, also refutes the contention that Congress intended "Alaska" to include the OCS. Those statutes allowed the new State of Alaska and Native Alaskans to select public lands "in Alaska" as their own. It is inconceivable that Congress could have intended that either the State or the Natives could select so vital a national resource as the OCS. P. 480 U. S. 555.
(d) ANILCA's legislative history indicates that OCSLA, rather than ANILCA, governs offshore oil development. Pp. 480 U. S. 552-554.
(e) The statutory construction rule that doubtful expressions must be resolved in favor of Indians does not apply here, since there is no ambiguity in the Act that requires interpretation. P. 480 U. S. 555.
774 F.2d 1414, reversed in part, vacated in part, and remanded.
WHITE, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and BRENNAN, MARSHALL, BLACKMUN, POWELL, and O'CONNOR, JJ., joined, and in Parts I and III of which STEVENS and SCALIA, JJ., joined. STEVENS, J., filed an opinion concurring in part and concurring in the judgment, in which SCALIA, J., joined, post, p. 480 U. S. 555.