Ventura County v. Gulf Oil Corporation

The question on appeal is whether the County of Ventura (“Ventura”) can require the federal Government’s lessee, Gulf Oil Corporation (“Gulf”), to obtain a permit from Ventura in compliance with Ventura’s zoning ordinances governing oil exploration and extraction activities before Gulf can exercise its rights under the lease and drilling permits acquired from the Government. The district court denied Ventura’s motion for a preliminary injunction, and dismissed Ventura’s second amended complaint. Ven-tura appeals. We uphold the district court because the local ordinances impermissibly conflict with congressional regulation of Gulf’s activities on government land.

On January 1, 1974, the Department of the Interior, Bureau of Land Management, pursuant to the Mineral Lands Leasing Act of 1920 ( 30 U.S.C. §§ 181 et seq.), leased 120 acres located within the Los Padres National Forest in Ventura for purposes of oil exploration and development. A subsequent assignment of this lease to Gulf was approved by the Department of the Interi- or, effective April 1,1974. On February 25, 1976, the United States Department of the Interior, Geological Survey, issued a permit approving Gulf’s…