BP America Production Co. v. Burton

This case served to clarify the concept of a statute of limitations. The Department of the Interior's Mineral Management Service issued notices demanding payment of royalty underpayments on gas leases on federal lands to the petitioners. The petitioners sued, believing that the statute of limitations prohibited this administrative action. They relied on 28 U. S. C. §2415(a) which states "[E]very action for money damages brought by the United States or an … agency thereof which is founded upon any contract … , shall be barred unless the complaint is filed within six years after the right of action accrues or within one year after final decisions have been rendered in applicable administrative proceedings." They appealed, first to the Assistant Secretary of the Interior, then on to the District Court and Court of Appeals.

The U.S. Supreme Court upheld the decisions of the lower court. The language of the aforementioned statute uses specifically judicial wording, including "action" "damages" and "complaint". Moreover, the usage of the term "administrative proceedings" would appear to distinguish court action from administrative ones. The court disagreed that the term "action" could apply to administrative actions as documents specifically modify the term action with clarifiers if the intent is to describe an administrative action. Furthermore, they also disagreed that a Mineral Management Service payment order was, in any way, a "complaint". Moreover, there is already a specific seven year statute of limitations in effect with regard to Mineral Management Service royalty payments. All justices present concurred on the opinion of the U.S. Supreme Court.

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