Legal Opinion
Independent Petroleum Ass'n of America v. Babbitt
Court of Appeals for the D.C. Circuit
Decided January 5, 2001No. 98-5131PublishedCited by 92 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
In the consolidated cases of Independent Petroleum Association of America v. Babbitt (Samedan Oil Corp. v. Deer), 92 F.3d 1248 (D.C.Cir.1996), we held that (1) a policy letter written by an Associate Director of the Minerals Management Service clarifying the royalty consequences of take-or-pay settlement payments was not a rule subject to the notice-and-comment requirements of the Administrative Procedure Act; and (2) the decision of an Assistant Secretary of the Department of the Interior in Samedan Oil Corp.,…
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3Cited by92 opinions
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