Case Explained: Wildcat Coal v. Pacific Minerals, et al.

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-11 Docket: 2:22-CV-00102-NDF) The Tenth Circuit affirmed in part, reversed in part, and remanded the case for further proceedings consistent with its opinion. The court held that a thirty-six-month protest provision in the Nine Mile Lease conclusively barred Wildcat Coal LLC from challenging royalty calculations made between 1986 and 2015, thereby reversing the district court’s sua sponte order requiring a full recalculation of those historical payments. However, the court affirmed the lower court’s conclusion that Bridger Coal Company could accumulate credits for payments exceeding contractual minimums to offset its advance royalty obligation for the 2016–2020 period and upheld the district court’s interpretation of “Adjoining Lands” to include both public and private leases, surface and underground mining operations, and all lands covered by a contiguous lease permit regardless of geographic proximity. The court applied Wyoming contract law principles, interpreting mineral leases according to general contract principles by reading the contract as a whole and enforcing clear, unambiguous language without inserting limitations not present in the text. Regarding the protest provision, the court reasoned that the lease’s conclusive presumption of correctness for payments and accounting statements applies unless a written exception is made within thirty-six months; because Wildcat failed to challenge the 1986–2015 calculations within this window, it was precluded from seeking retroactive adjustments. The court further determined that the district court did not err in rejecting Bridger’s arguments that “Adjoining Lands” excluded private leases or underground mining, noting that Section 15 of the lease merely established a surrender process for government lands without excluding private lands from the definition, and that Section 26 of the Ten Mile Lease governed mining operations rather than defining “Adjoining Lands.” Finally, the court clarified that the term “contiguous leases” in Recital 3 meant that any lease containing land contiguous to the primary tract qualified as an “Adjoining Land,” thereby including all lands within that lease even if those specific parcels were not geographically adjacent. The practical consequence is that Bridger Coal Company must recalculate its royalty obligations only for the 2016–2020 period using the court’s broad definition of “Adjoining Lands,” while retaining the right to withhold payments equal to any credits accumulated from overpayments made between 1986 and 2015. The case is remanded to the District Court for the District of Wyoming to enter a judgment consistent with these findings, effectively limiting the scope of the recalculation dispute to the five-year period in question rather than the entire lease term. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.