## Facts

- Private landholders, including Union Oil, owned or leased lands at “The Geysers” in Sonoma County, California, an area containing subsurface geothermal steam.
- The landholders developed or intended to develop wells to produce geothermal steam for electricity generation.
- The lands were patented under the Stock-Raising Homestead Act of 1916 (SRHA), which reserved to the United States “all the coal and other minerals” and the right to prospect for, mine, and remove them.
- Acting under the Geothermal Steam Act of 1970, the Attorney General filed a quiet title action to determine whether the SRHA mineral reservation included geothermal resources.
- The district court held geothermal resources were not included in the SRHA reservation and entered judgment for the landholders.

## Issues

1. Whether the SRHA reservation of “all the coal and other minerals” in patented lands includes geothermal resources (subsurface hot water/steam used as an energy source).

## Decision

- The Ninth Circuit reversed and remanded.
- The court held geothermal resources underlying SRHA-patented lands are “minerals” reserved to the United States.
- The district court’s judgment quieting title in the landholders was set aside for further proceedings consistent with federal ownership of the geothermal mineral estate.

## Legal Principles

- Interpretation of “minerals” in a federal land patent reservation turns primarily on congressional intent within the statutory setting, not a purely scientific classification.
- The SRHA created a split estate intended to convey surface uses for stock raising and agriculture while reserving valuable subsurface resources to the United States for later disposition.
- “Coal and other minerals” in SRHA reservations is construed broadly to include subsurface energy resources; geothermal steam is functionally comparable to other energy minerals.
- Geothermal resources are treated as an energy resource distinct from ordinary water rights because their economic value derives from subsurface heat and steam used for power generation.

## Conclusion

The Ninth Circuit held that geothermal resources beneath lands patented under the SRHA fall within the Act’s reservation of “all the coal and other minerals,” so the geothermal steam resource is part of the federally reserved mineral estate rather than the surface owners’ property.


United States v. Union Oil Co. of Cal., 549 F.2d 1271 (9th Cir. 1977)