In The United States District Court For The Western District of Oklahoma
In The United States District Court For The Western District of Oklahoma
In The United States District Court For The Western District of Oklahoma
1. STATE OF OKLAHOMA,
3. OKLAHOMA DEPARTMENT OF
MINES, Civil Action No: CIV-21-719-F
4. OKLAHOMA CONSERVATION
COMMISSION,
Plaintiffs,
v.
Defendants.
I. INTRODUCTION
Plaintiffs the State of Oklahoma, Kevin Stitt, in his official capacity as Governor of
Commission (“OCC”) (together, “Plaintiffs”) seek relief from Defendants’ May 18, 2021
Notice of Decision through which Defendants purport to unlawfully strip Oklahoma of its
jurisdiction to regulate surface coal mining and reclamation operations under Titles IV and
V of the Surface Mining Control and Reclamation Act (“SMCRA” or the “Act”) and to
impose a Federal program in its place within the historic lands of the Muscogee (Creek)
Nation. Without any process whatsoever and virtually no legal analysis, the Department
of the Interior, through the Office of Surface Mining Reclamation and Enforcement
(“OSMRE”), asserts that the State of Oklahoma lacks the legal authority under SMCRA to
expansion of the U.S. Supreme Court’s decision in McGirt v. Oklahoma, 140 S. Ct. 2452
(2020), a decision that the Supreme Court explicitly limited to the application of federal
criminal law under the Major Crimes Act. Disregarding this express limitation, Defendants
contend that Oklahoma, after successfully implementing, enforcing, and maintaining its
SMCRA programs for over 30 years, now lacks jurisdiction to administer its programs
within the historic lands of the Muscogee (Creek) Nation. In furtherance of its unlawful
decision to strip Oklahoma of its SMCRA programs, OSMRE informed ODM that OSMRE
does not intend to authorize the distribution of ODM’s remaining grant funds for 2021 and
denied OCC’s applications for abandoned mine land (AML) program grant funding
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(“Grant Funding Denials”), which OSMRE must provide to states with approved SMCRA
Defendants are wrong. The holding in McGirt is explicitly limited to the statutory
definition of “Indian country” as it applies in federal criminal law under the Major Crimes
Act. McGirt, 140 S. Ct. at 2480. The holding does not extend outside of that limited
Real and justiciable controversies exist between Plaintiffs and Defendants over
whether McGirt applies outside of the limited context of federal criminal law, and whether
Oklahoma has jurisdiction for the regulation of surface coal mining and reclamation
operations under Titles IV and V of SMCRA within the historic lands of the Muscogee
(Creek) Nation. OSMRE’s unlawful notice does not even mention, let alone analyze, these
important questions of law. Declaratory and injunctive relief are requested to resolve these
controversies.
required process under the APA for taking final agency action and the required process
under SMCRA for disapproving a State program and preparing a Federal program.
with law in violation of SMCRA and the APA, Plaintiffs ask the Court to vacate the Notice
of Decision and the Grant Funding Denials and enjoin Defendants from acting further
under both.
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1331 because Plaintiffs’ claims arise under the laws of the United States, including
2. This Court has authority to declare the rights of any interested party
to administer its approved State program under SMCRA within the historic lands of the
Muscogee (Creek) Nation, to prepare a Federal program in its place, and to deny funding
on that basis. This creates an actual, justiciable controversy between the parties.
remedy at law.
7. With respect to the claims arising under SMCRA, venue lies exclusively in
this Court pursuant to 30 U.S.C. § 1276(a)(1) because the capital of Oklahoma is located
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III. PARTIES
Oklahoma.
Oklahoma (“Governor”). The Governor oversees Plaintiff ODM and Plaintiff OCC.
10. Plaintiff ODM enforces and implements various provisions of state- and
11. Plaintiff OCC administers the State program for reclaiming abandoned mine
the Interior is an agency within the meaning of the APA. See 5 U.S.C. § 551(1). The
Secretary and the Department of the Interior are charged at the federal level with
13. Defendant Glenda Owens is named in her official capacity as the Acting
Director of the OSMRE (“Director”). Defendant OSMRE is an agency within the meaning
of the APA. See 5 U.S.C. § 551(1). Defendant OSMRE is a bureau of the Department of
the Interior charged with administering SMCRA, including overseeing the implementation
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of State programs. 30 U.S.C. § 1211(b), (c). Defendant Owens issued the May 18, 2021
Notice of Decision.
14. Congress enacted SMCRA in 1977 to ensure, among other things, “that
surface coal mining operations are so conducted as to protect the environment,” and to
“strike a balance between protection of the environment and agricultural productivity and
the Nation’s need for coal as an essential source of energy.” 30 U.S.C. § 1202(d), (f).
SMCRA regulates the overall construction, operation, and reclamation of surface coal
15. Section 201 of SMCRA established the OSMRE in the Department of the
Interior. 30 U.S.C. § 1211(a). Congress created the OSMRE as the agency through which
the Secretary exercises her responsibility for administering and implementing SMCRA.
16. SMCRA created two major programs: (1) an AML reclamation program,
funded by fees that operators pay on each ton of coal produced, to reclaim land and water
resources adversely affected by coal mines abandoned before August 3, 1977, 30 U.S.C.
§§ 1231–1244 (“Title IV”), and (2) a regulatory program to ensure that surface coal mining
operations initiated or in existence after the effective date of the Act are conducted and
17. Title IV of SMCRA mandates that OSMRE provide AML grants to eligible
States and Tribes that are funded from permanent (mandatory) appropriations. See id. §
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1232. All coal operators pay fees to the Secretary of the Interior for deposit in the
Abandoned Mine Reclamation Fund. Id. § 1232(a). States receive a percentage allocation
of the fees collected in the State. Id. § 1232(g). To be eligible for the grant, the State must
1235(c).
18. Title V of SMCRA authorizes OSMRE to provide grants to States and Tribes
to develop, administer, and enforce State and Tribal regulatory programs that address,
among other things, the disturbances from coal mining operations. See id. § 1295.
the environment from the adverse effects of surface coal mining operations,” id. § 1202(a),
20. To carry out its intent that States assume primary authority to develop, issue,
and enforce regulations governing coal mining and reclamation operations, Congress
included within SMCRA a program of cooperative federalism that allows States to assume
primary responsibility for the regulation of surface coal mining and reclamation within
their borders, subject only to very limited oversight from OSMRE. This primary
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21. To obtain primacy, a State must propose a regulatory program showing that
it has, among other things: (1) “a State law which provides for the regulation of surface
coal mining and reclamation operations in accordance with [the Act]”; (2) “a State law
permits”; (3) “a State regulatory authority with sufficient administrative and technical
personnel”; (4) “a State law which provides for the effective implementations,
maintenance, and enforcement of a permit system”; (5) “a process for coordinating the
review and issuance of permits for surface coal mining and reclamation operations with
any other Federal or State permit process applicable to the proposed operations”; and (6)
“rules and regulations consistent with regulations issued by the Secretary pursuant to [the
Act].” Id. § 1253(a). The Secretary, through OSMRE, must review and approve or not
22. Once the State has obtained approval of its program, State laws and
regulations implementing SMCRA “become operative for the regulation of surface coal
mining, and the State officials administer the program, . . . giving the State ‘exclusive
jurisdiction over the regulation of surface coal mining’ within its borders.” Bragg v. W.
Va. Coal Ass’n, 248 F.3d 275, 288 (4th Cir. 2001) (quoting 30 U.S.C. § 1253(a)).
its approved State program as provided for in this [Act],” then the Secretary shall prepare
a Federal program “for the regulation and control of surface coal mining and reclamation
operations taking place on lands within any State not in compliance with this Act.” 30
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program, the Secretary shall give adequate public notice and hold a public hearing in the
Id. § 1276(a)(l).
25. Once a State obtains primacy, any alteration of an approved State program,
referred to as an “amendment,” must follow the procedure set forth in 30 C.F.R. § 732.17.
State program,” or “indicate that the approved State program no longer meets the
requirements of the Act,” then the Director must determine whether a State program
amendment is required and notify the State regulatory authority of the decision. 30 C.F.R.
§ 732.17(c), (e).
27. If an amendment is required, the State shall, within 60 days after notification
the State does not submit a proposed amendment within 60 days, then the Director must
begin proceedings under 30 C.F.R. § 733 “if the Director has reason to believe that such
maintaining or enforcing all or part of its approved State program.” Id. § 732.17(f)(2).
28. 30 C.F.R. § 733 provides the procedure for substituting Federal enforcement
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written notice to the State, the opportunity for an informal hearing, and public notice and
hearing. See id. § 733.13(b), (c), (d). If, upon review of the hearing and “all available
information, including the hearing transcript, written presentations and written comments,”
the Director concludes that the State has failed to implement, administer, maintain or
enforce effectively all or part of the approved program, then the Director may substitute
Federal enforcement of the State program or recommend to the Secretary that she withdraw
approval of the State program. Id. § 733(e). If the Director decides to substitute Federal
enforcement of a State program, then the Director must give public notice of its findings.
Id. § 733.13(f).
29. On February 28, 1980, Oklahoma, through the ODM, submitted the
necessary proposed State program required by 30 U.S.C. § 1253(a) to the Secretary for
approval.
30. After providing significant opportunities for public review and comment and
holding public hearings, OSMRE conditionally approved Oklahoma’s State program under
Title V on January 19, 1981. See 45 Fed. Reg. 67,361-62 (Oct. 10, 1980); 46 Fed. Reg.
4,902 (Jan. 19, 1981). After further public hearings and conferences between Oklahoma
and OSMRE, OSMRE approved Oklahoma’s permanent regulatory program. 47 Fed. Reg.
31. Oklahoma’s Title V program has been amended pursuant to the procedures
set forth in 30 C.F.R. § 732 twenty-eight (28) times. See 30 C.F.R. § 936.15.
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32. Oklahoma, through the OCC, also has an approved State program under Title
IV for abandoned mine reclamation. See id. § 936.20. That plan has been effective since
33. With approved State programs for both coal mining and reclamation,
allow ODM to also regulate mining on federal lands. See 30 C.F.R. § 936.30. The
Governor of Oklahoma and the Secretary signed the agreement in August 1989, and it was
approved State SMCRA programs for over 30 years. See 52 Fed. Reg. 36,922 (Oct. 2,
35. Since approval of both programs, Oklahoma has received (and relies upon)
AML grants and regulatory program grants to help fund the programs.
McGirt v. Oklahoma
36. On July 9, 2020, the U.S. Supreme Court issued its decision in McGirt v.
Oklahoma, 140 S. Ct. 2452 (2020). The case came on a writ of certiorari to the Oklahoma
Court of Criminal Appeals (“OCCA”), the State’s court of last resort for criminal matters.
37. The case concerned whether Oklahoma state courts had jurisdiction to try a
citizen of the Creek Nation for certain criminal offenses. Id. at 2459-60. The Court
reversed the OCCA’s decision in a 5-4 ruling, holding that for the purposes of prosecuting
criminal offenses under the federal Major Crimes Act (“MCA”), the historic lands of the
Muscogee (Creek) Nation in eastern Oklahoma constituted “Indian country.” Id. at 2460-
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82. As a result, the State of Oklahoma lacked jurisdiction to prosecute crimes committed
by an Indian because the crimes occurred on lands that constituted “Indian country” under
38. By its terms, the holding of McGirt was restricted to “purposes of federal
criminal law.” Id. at 2459. McGirt did not address questions about regulatory jurisdiction
within the historic lands of the Muscogee (Creek) Nation. In fact, the Supreme Court
disavowed those questions, stating that “[t]he only question before us … concerns the
statutory definition of ‘Indian country’ as it applies in federal criminal law under the [Major
however, the Supreme Court’s holding in McGirt does not extend to Oklahoma’s primacy
under SMCRA to regulate surface coal mining operations and reclamation within the
40. On April 2, 2021, OSMRE sent letters to ODM and OCC stating that,
pursuant to McGirt, “OSMRE and the Secretary of the Interior lack the authority to confer
on the State of Oklahoma jurisdiction over lands within the exterior boundaries of the
Muscogee (Creek) Nation Reservation.” Letter from OSMRE to Oklahoma Energy and
Environment dated Apr. 2, 2021, attached as Exhibit 1; Letter from OSMRE to OCC dated
Apr. 2, 2021, attached as Exhibit 2. Accordingly, OSMRE asserted that “the State of
Oklahoma may no longer administer a SMCRA regulatory program on lands within the
exterior boundaries of the Muscogee (Creek) Nation Reservation.” Id. OSMRE asserted
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that “[f]or lands within the exterior boundaries of the Muscogee (Creek) Nation
41. The Oklahoma Attorney General responded to OSMRE’s letters on April 16,
2021, explaining that “OSMRE’s assertion of sole and exclusive jurisdiction is not well-
supported by the legal citations offered in your letters.” Letter from Mike Hunter to Glenda
Owens dated Apr. 16, 2021, attached as Exhibit 3. The Oklahoma Attorney General
explained that because OSMRE’s “demand appears to have no adequate basis in law, I am
advising that no state agency should comply with it without further discussion.” Id.
42. On May 18, 2021, OSMRE published a one-page “Notice of Decision” in the
Federal Register stating that pursuant to McGirt, OSMRE “is assuming jurisdiction over
the SMCRA Title IV reclamation and Title V regulatory programs.” 86 Fed. Reg. 26,941
43. Based on the same assertions as in its Notice of Decision, on June 29, 2021,
OSMRE informed ODM that it does not intend to authorize the distribution of ODM’s
remaining grant funds for calendar year 2021. Letter from ODM to M. Mansinghani and
44. Based on the same assertions as in its Notice of Decision, on July 8, 2021,
OSMRE denied OCC’s application for the FY2021 AML grant and the amendment request
to add carry over funding to the FY2020 AML grant. Email from GrantSolutions to OCC
dated July 8, 2021, attached as Exhibit 5 (together with Ex. 4, “Grant Funding Denials”).
45. Moreover, OSMRE is refusing to allow ODM to access grant funding that
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46. Unlike the lengthy, formal public process employed to establish the
Oklahoma program and to make various amendments to the Oklahoma program throughout
the last 30 years, OSMRE amended the Oklahoma program to exclude the historic lands of
the Muscogee (Creek) Nation with a stroke of the pen behind closed doors. OSMRE did
not conduct an informal or formal hearing with Plaintiffs or the public prior to issuing the
Notice of Decision or the Grant Funding Denials. Nor did OSMRE provide an opportunity
for public review and comment prior to issuing the Notice of Decision or Grant Funding
Denials.
47. The Notice of Decision and Grant Funding Denials contain only conclusory
statements and provide no detailed findings of fact or legal reasoning to support the
conclusion that McGirt—a decision that by its terms is restricted to “purposes of federal
48. Plaintiffs and the public have already suffered and will continue to suffer
severe and irreparable harm from the Notice of Decision and the Grant Funding Denials.
sovereignty over the historic lands of the Muscogee (Creek) Nation, which are within
50. Second, the Notice of Decision impermissibly strips Oklahoma of its primacy
by unlawfully transferring that authority to the Federal government. The statutory and
constitutional limitations on the authority of federal agencies protect citizens from the
intrusion of the federal government into areas where local knowledge is critical to
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designing effective rules and policies. As SMCRA recognized, the regulation of mining is
such an area. By displacing local regulatory authority in a manner inconsistent with the
purpose of the statute, the Notice of Decision impedes, rather than advances, efforts to
balance the importance of coal to the nation’s economy with environmental considerations.
51. Third, the Grant Funding Denials eliminate the federal funding guaranteed
to Oklahoma under Titles IV and V of SMCRA. The federal grant for fiscal year 2020
(which ended on June 30, 2021) was approximately $2.8 million for OCC, but OSMRE is
unlawfully denying any grant or grant amendment for FY2021. The federal grant for
calendar year 2021 (which ends December 31, 2021) is approximately $1.3 million for
52. Fourth, because OSMRE has cut off federal funding to Oklahoma for the
SMCRA programs, ODM and OCC will be forced to reduce their workforce and thus
continue to implement and enforce their lawful SMCRA programs throughout the State,
including within the historic lands of the Muscogee (Creek) Nation, with limited staff and
resources.
53. Fifth, the Notice of Decision deprives Oklahoma of the ability to assess civil
penalties for cessation orders and notices of violation for noncompliant mining activities
within the historic lands of the Muscogee (Creek) Nation, thus reducing the funds
Oklahoma would otherwise have to allocate to reclamation projects across the State. See
to a declaratory judgment and vacatur of the Notice of Decision and the Grant Funding
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55. An injunction is warranted and would serve the public interest because the
Notice of Decision and Grant Funding Denials impair Oklahoma’s ability to protect land
and water resources in accordance with local needs; threaten the existence of an industry
Congress found “essential to the national interest,” 30 U.S.C. § 1201(b); and have the
potential to impose significant monetary and environmental costs on the State, businesses,
and citizens.
56. Plaintiffs’ rights will be permanently impaired, and Defendants will continue
to implement and enforce the illegal Notice of Decision and the Grant Funding Denials,
Declaratory Judgment that McGirt Does Not Apply to Surface Coal Mining and
Reclamation Activities and that Oklahoma Has Jurisdiction Under SMCRA to
Regulate Surface Coal Mining and Reclamation Operations Within the Historic
Lands of the Muscogee (Creek) Nation
59. The Supreme Court’s holding in McGirt was limited to “the statutory
definition of ‘Indian country’ as it applies in federal criminal law under the [Major Crimes
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60. McGirt does not reach any conclusions outside of this limited context.
61. Due to its limited holding, McGirt does not bar Oklahoma from exercising
its regulatory jurisdiction over surface coal mining and reclamation operations under Titles
IV and V of SMCRA within the historic lands of the Muscogee (Creek) Nation.
62. Defendants assert in the Notice of Decision that under McGirt, the State of
lands of the Muscogee (Creek) Nation. See 86 Fed. Reg. 26,941. On that basis, Defendants
summarily assert that “OSMRE is assuming jurisdiction over SMCRA Title IV reclamation
63. A real, justiciable controversy exists between Plaintiffs and Defendants over
whether McGirt applies to surface coal mining and reclamation operations or, at a
minimum, a real, justiciable controversy exists between Plaintiffs and Defendants over
whether Oklahoma has jurisdiction over surface coal mining and reclamation operations
under Titles IV and V of SMCRA within the historic lands of the Muscogee (Creek) Nation.
64. Plaintiffs seek a declaratory judgment that Oklahoma has jurisdiction over
surface coal mining and reclamation operations under Titles IV and V of SMCRA within
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66. The APA provides for judicial review of final agency action by persons
67. The actions reviewable under the APA include “preliminary, procedural, or
intermediate agency action or ruling . . . on the review of the final agency action,” such as
68. Under the APA, this Court has the authority to “hold unlawful and set aside
discretion, or otherwise not in accordance with law,” id. § 706(2)(A), and to set aside an
agency decision made “without observance of procedure required by law,” id. § 706(2)(D).
69. Agency action is arbitrary and capricious when the agency engages in no
careful and searching inquiry into the facts that support the agency’s decision. See Encino
Motorcars, LLC v. Navarro, 136 S. Ct. 2117, 2125 (2016) (“The agency must examine the
relevant data and articulate a satisfactory explanation for its action including a rational
connection between the facts found and the choice made.”) (internal citation and quotation
marks omitted).
problems and matters that were raised by the Oklahoma Attorney General in his April 16,
2021 letter. See Ex. 3; Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins., 463 U.S.
29, 43 (1983) (agency action is “arbitrary and capricious if the agency … entirely failed to
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72. Defendants did not conduct an informal or formal hearing prior to issuing the
Notice of Decision.
73. Defendants did not provide an opportunity for public comment prior to
Implications of Substitution of Federal Authority,” the Notice of Decision merely sets forth
the purposes of Title IV and Title V of SMCRA. The Notice of Decision contains no actual
that no searching and careful inquiry was conducted, and Defendants provided no detailed
factual or legal basis to support the conclusion that McGirt deprives Oklahoma of its
regulatory jurisdiction over surface coal mining and reclamation operations under Titles
IV and V of SMCRA within the historic lands of the Muscogee (Creek) Nation.
inconsistent with law, because Defendants erroneously interpreted McGirt to apply outside
of its limited context (federal criminal law) and to deprive Oklahoma of its regulatory
jurisdiction over surface coal mining and reclamation operations under Titles IV and V of
77. McGirt does not bar the State of Oklahoma from exercising its regulatory
jurisdiction over surface coal mining and reclamation operations under Titles IV and V of
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designate OSMRE as the regulatory authority over surface coal mining and reclamation
operations on Indian lands where a tribe has not obtained primacy. SMCRA does not
capricious, an abuse of discretion, or otherwise not in accordance with law. Plaintiffs are
81. Under the APA, this Court has the authority to “hold unlawful and set aside
discretion, or otherwise not in accordance with law,” 5 U.S.C. § 706(2)(A), and to set aside
706(2)(D).
82. Defendants issued the Grant Funding Denials without adequate explanation,
83. Defendants did not conduct an informal or formal hearing prior to issuing the
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84. Defendants did not provide an opportunity for public comment prior to
Denials.
indicates that no searching and careful inquiry was conducted, and Defendants provided
87. Defendants’ Grant Funding Denials are inconsistent with law, because
Defendants relied on the unlawful Notice of Decision to issue the Grant Funding Denials.
88. The Grant Funding Denials are arbitrary, capricious, an abuse of discretion,
or otherwise not in accordance with law. Plaintiffs are therefore entitled to the relief
requested below.
91. For the reasons set forth above, Defendants’ Notice of Decision is arbitrary,
capricious, and otherwise inconsistent with law in violation of SMCRA, id. § 1276(a),
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94. The APA requires the reviewing court to hold unlawful and set aside agency
95. All rules must be adopted in accordance with the APA. See id. § 553.
96. The APA defines “rulemaking” as the “agency process for formulating,
97. The APA defines a “rule” as “the whole or a part of an agency statement of
of an agency and includes the approval or prescription for the future of rates, wages,
on any of the foregoing.” Id. § 551(4). In short, an agency creates a rule when it seeks to
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existing law or policy.” Mendoza v. Perez, 754 F.3d 1002, 1021 (D.C. Cir. 2014); see
also Shalala v. Guernsey Mem’l Hosp., 514 U.S. 87, 100 (1995).
99. The Notice of Decision published by OSMRE on May 18, 2021 in the Federal
Register purporting to disapprove Oklahoma’s SMCRA programs for the historic lands of
the Muscogee (Creek) Nation and instead prepare a Federal program for those lands is a
final agency action that falls within the definition of a “rule” because such an action
constitutes both “a statement of general or particular applicability and future effect” which
It also clearly “adopts a new position inconsistent with existing regulations” regarding the
Mendoza, 754 F.3d at 1021; see also Ohio River Valley Envtl. Coal., Inc. v. Kempthorne,
473 F.3d 94, 102 (4th Cir. 2006) (holding that OSMRE’s approval of a State program
100. The APA sets forth the process for rulemaking with which agencies must
comply. 5 U.S.C. § 553. First, an agency must give notice of a proposed rulemaking,
published in the Federal Register. Id. § 553(b). The notice must include the date the rule
will come into effect, the legal authority the agency has proposed the rule under, and the
substance of the rule. Id. After notice is given, the agency is required to solicit and accept
public comments on the rule. Id. § 553(c). Finally, the agency must consider all comments
that are submitted in passing the final rule and include a “general statement of [the rule’s]
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101. Defendants failed to comply with any of the requirements set forth in the
APA. Defendants did not provide notice of the intended rulemaking, did not provide the
opportunity for public comment, and did not prepare or publish a statement of the rule’s
and Defendants failed to comply with any of the requirements set forth in the APA for an
adjudication.
103. Plaintiffs are permitted to challenge the Notice of Decision under the APA
because they have suffered a legal wrong and have been adversely affected and aggrieved
104. Defendants’ failure to follow the required procedures for either a rulemaking
or an adjudication violates the APA, entitling Plaintiffs to the relief requested below.
106. For the reasons stated in the above Claims for Relief, Defendants’ actions in
issuing the Notice of Decision and Grant Funding Denials violated Plaintiffs’ rights to
fairness and due process, Plaintiffs are entitled to the relief requested below.
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apply outside of the limited context expressly articulated by the Supreme Court
and that Oklahoma has jurisdiction over surface coal mining and reclamation
operations under Titles IV and V of SMCRA within the historic lands of the
as set forth above, are arbitrary and capricious, an abuse of discretion, and
Decision is unlawful because it was issued in violation of SMCRA and the APA;
d) Vacate and set aside the May 18, 2021 Notice of Decision;
e) Vacate and set aside the June 29, 2021 and July 8, 2021 Grant Funding Denials
further grant awards to ODM and OCC or amendments to existing grants on the
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h) Such other relief as the Court may deem just and proper.
Respectfully submitted,
s/ Mithun Mansinghani
Mithun Mansinghani
Solicitor General
Bryan Cleveland
Assistant Solicitor General
Jennifer Lewis
Assistant Attorney General
OKLAHOMA OFFICE OF THE ATTORNEY
GENERAL
313 NE 21st Street
Oklahoma City, OK 73105
Phone: (405) 521-3921
[email protected]
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David C. McSweeney
(OK Bar No. 31320)
(Pro Hac Vice Forthcoming)
HUNTON ANDREWS KURTH LLP
60 State Street, Suite 2400
Boston, MA 02109
Phone: (617) 648-2800
[email protected]
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