## Facts

- The Jicarilla Apache Tribe entered federal oil-and-gas leases covering reservation lands under Indian mineral leasing statutes, subject to approval and administration by the Secretary of the Interior.
- The Tribe alleged three categories of lease mismanagement by the Secretary and lessees:
  - Royalties were miscalculated or collected contrary to the royalty terms, regulations, and approvals governing the leases.
  - Lessees failed to diligently develop leased lands, and the Secretary failed to require development in accordance with lease and regulatory requirements.
  - Tribal gas was drained by offset production, and the Secretary failed to prevent or remedy drainage.
- The Tribe framed the asserted failures as breaches of the United States’ fiduciary obligations in administering Indian mineral leases.
- The district court found fiduciary breaches on the royalty, development, and drainage theories and awarded relief.
- A Tenth Circuit panel largely affirmed the judgment but rejected use of a broad private-trustee standard for fiduciary duty, applying administrative-law review to the Secretary’s actions.
- The Tenth Circuit reheard the case en banc to resolve the scope of the Secretary’s fiduciary obligations and the proper standard for judicial review.

## Issues

1. Whether the Secretary’s administration of Indian mineral leases is governed by a broad private-trustee duty to maximize tribal economic return, or by duties defined and limited by applicable statutes, regulations, and lease terms.
2. What standard of judicial review applies to the Secretary’s discretionary leasing-related decisions challenged as fiduciary breaches.
3. To what extent claims concerning royalties, diligent development, and drainage are enforceable only when grounded in specific statutory, regulatory, or contractual obligations.

## Decision

- The en banc court held that the United States acts in a fiduciary capacity in administering tribal mineral leases, but the content and limits of that duty derive from the governing statutes, regulations, and the leases themselves.
- The court rejected an open-ended private-trustee standard that would impose a generalized duty to maximize tribal revenues beyond the governing legal instruments.
- The court applied administrative-law principles to review the Secretary’s actions, asking whether decisions were arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law when measured against the relevant statutory, regulatory, and contractual framework.
- The court determined the district court erred to the extent it imposed fiduciary obligations untethered to specific duties created by statute, regulation, or the lease terms.
- The disposition modified the district court’s judgment accordingly, resulting in affirmance in part, reversal in part, and remand to conform the relief and analysis to the limited, source-based fiduciary duty and APA-style review.

## Legal Principles

- The federal-tribal trust relationship in mineral leasing does not itself create free-standing fiduciary duties; enforceable duties must be found in specific statutes, regulations, and lease provisions that establish responsibilities.
- Indian mineral leasing statutes authorize leasing with Secretarial approval and contemplate tribal contracting authority; the Secretary’s role is supervisory and administrative as defined by the governing scheme.
- Courts do not substitute generalized trust-law notions for the statutory and contractual allocation of responsibilities in Indian mineral leasing.
- Challenges to the Secretary’s discretionary administration of leases are evaluated under administrative-law standards, focusing on compliance with governing legal requirements and reasoned decisionmaking.
- Claims involving royalty administration, development enforcement, and drainage protection require identification of concrete legal obligations; liability cannot rest solely on a generalized duty to obtain the best economic outcome.

## Conclusion

The en banc Tenth Circuit held that while the Secretary’s administration of tribal mineral leases occurs within a fiduciary relationship, the Secretary’s enforceable obligations are bounded by the specific statutes, regulations, and lease terms governing the leases, and judicial review proceeds under administrative-law standards rather than a broad private-trustee duty to maximize tribal revenues.


Jicarilla Apache Tribe v. Supron Energy Corp., 782 F.2d 855 (10th Cir. 1986) (en banc)