Arkla Exploration Co. v. Texas Oil & Gas Corp.
Court of Appeals for the Eighth Circuit
1Opinion of the Court
BOWMAN, Circuit Judge.
Under the Mineral Lands Leasing Act (MLA), 30 U.S.C. §§ 181-287, before government lands may be leased for oil or gas exploration without competitive bidding, the Secretary of the Interior (the Secretary) must determine that the lands are not within a “known geological structure of a producing oil or gas field” (KGS). Id. at § 226. At issue in this case is whether the Secretary made a proper KGS determination before granting valuable oil and gas exploration leases to Texas Oil and Gas Corporation (TXO) on a noncompetitive basis. The District Court for the Western…
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