25 U.S.C. § 398A
Section 398a · Leases of unallotted lands for oil and gas mining purposes within Executive order Indian reservations
Amended 1 time on record
Applied in 7 court decisions — leading case Merrion v. Jicarilla Apache Tribe (1982)
Most recently applied in Ute Mountain Ute Tribe v. Rodriguez (July 2011)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Unallotted lands within the limits of any reservation or withdrawal created by Executive order for Indian purposes or for the use or occupancy of any Indians or tribe may be leased for oil and gas mining purposes in accordance with the provisions contained in section 398 of this title.