30 U.S.C. § 226
Section 226 · Limitations for filing oil and gas contests
Amended 2 times on record
Applied in 34 court decisions — leading case Seymour v. Summa Vista Cinema, Inc. (1987)
Most recently applied in Southern Utah Wilderness Alliance v. United States Department of Interior (March 2017)
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.
No action contesting a decision of the Secretary involving any oil and gas lease shall be maintained unless such action is commenced or taken within ninety days after the final decision of the Secretary relating to such matter. No such action contesting such a decision of the Secretary rendered prior to September 2, 1960 shall be maintained unless the same be commenced or taken within ninety days after September 2, 1960.