United States v. Midwest Oil Co.

Under the Oil Placer Act of 1897, private parties rapidly extracted oil from public lands until a 1909 government report warned this pace would force the government to buy back oil for the Navy, prompting the President to temporarily withdraw certain oil-bearing public lands, including land in Wyoming, from private acquisition pending proposed legislation. In 1910, Midwest Oil Company (Midwest) (defendant) extracted large amounts of oil from the withdrawn Wyoming land anyway, and the government sued in equity to recover the land and an accounting of the extracted oil, arguing the withdrawal was validly authorized by executive power combined with Congress's tacit consent. The district court dismissed the government's suit, and the case reached the Supreme Court on certification.