## Facts

- The Bureau of Land Management leased 120 acres of federal land in the Los Padres National Forest (within Ventura County) for oil exploration and development under the Mineral Leasing Act of 1920.
- The federal lease was assigned to Gulf Oil Corporation with federal approval effective April 1, 1974.
- Federal agencies issued drilling-related authorizations, including a Geological Survey drilling permit and Forest Service approvals; California’s Division of Oil and Gas also approved the proposed exploration.
- Gulf commenced drilling operations on April 28, 1976, and continued exploration and development activities on the leased property.
- Ventura County zoned the leased property as “Open Space (O‑S)” and prohibited oil exploration and extraction on O‑S land unless an “Open Space Use Permit” was obtained from the county planning authority.
- The county permit scheme imposed mandatory conditions and allowed additional discretionary conditions; permits could be limited in duration and conditioned based on the “public interest.”
- Gulf did not obtain the county permit, relying on its federal lease rights and federal permits.
- Ventura sued in federal district court seeking a preliminary injunction to halt Gulf’s operations and to require compliance with county permitting; the district court denied injunctive relief and dismissed Ventura’s second amended complaint.

## Issues

1. Whether a county may require a federal mineral lessee to obtain and comply with a local zoning/open-space use permit before conducting federally authorized drilling on federal land.
2. Whether the county’s permit scheme is preempted under the Supremacy Clause because it conflicts with, or poses an obstacle to, the federal mineral leasing and permitting program governing development on federal lands.

## Decision

- The Ninth Circuit affirmed the denial of a preliminary injunction and the dismissal of Ventura’s complaint.
- The court held the county ordinances were preempted because they impermissibly conflicted with congressional regulation of oil and gas activities conducted on federal lands under a federal lease and federal drilling approvals.
- The Supreme Court summarily affirmed the Ninth Circuit’s judgment.

## Legal Principles

- State and local law is preempted where it conflicts with federal law or stands as an obstacle to accomplishing Congress’s objectives.
- When Congress establishes a detailed federal regulatory regime for mineral leasing and development on federal lands, local permitting systems that operate as an additional precondition to federally authorized operations are invalid if they can delay, alter, or effectively veto federal decisions.
- Local land-use and environmental interests do not authorize discretionary local approval schemes that materially interfere with federal control and administration of mineral development on federal property, particularly where federal agencies regulate environmental and operational conditions through federal permits and oversight.

## Conclusion

The court concluded that Ventura County could not require Gulf, a federal mineral lessee operating under federal leases and drilling approvals on federal land, to secure a county open-space use permit, because the county’s discretionary permitting and condition-setting regime conflicted with and obstructed the federally governed mineral leasing program.


Ventura County v. Gulf Oil Corp., 601 F.2d 1080 (9th Cir. 1979), aff'd, 445 U.S. 947 (1980)