The U.S. Supreme Court case Amoco Production Co. et al. v. Village of Gambell et al., 1986, revolved around the leasing of offshore lands by the Secretary of Interior for oil and gas exploration near Alaska's St Lawrence Island without conducting an environmental impact study (EIS). The local Inupiat Eskimo community and city officials from Gambell challenged this decision, arguing that it violated the National Environmental Policy Act (NEPA) and the Alaska National Interest Lands Conservation Act (ANILCA). The District Court granted a preliminary injunction to halt exploratory activities until an EIS was conducted, which was upheld by Appeals court as well. However, in a unanimous decision led by Justice White, the Supreme Court reversed these rulings stating that neither NEPA nor ANILCA required completion of an EIS before granting leases for exploratory drilling; they only necessitated "hard look" at potential impacts prior to any 'major federal action' causing significant changes to environment - something not guaranteed merely with lease issuance itself.

In the dissenting opinion for AMOCO Production Co. et al. v. Village of Gambell et al., Justice Stevens argued that the majority's interpretation of Section 810 of the Alaska National Interest Lands Conservation Act (ANILCA) was incorrect and overly narrow, potentially undermining environmental protections in favor of economic interests. He contended that ANILCA required a full evaluation and consideration not just for major federal actions but also minor ones, including exploratory drilling by oil companies like Amoco Production Co., to ensure they would not significantly restrict subsistence needs or resources before proceeding with such activities on public lands in Alaska. Furthermore, he disagreed with the majority's view that preliminary injunctions should be rarely used in these cases; instead, he believed courts should have more discretion to issue them when necessary to prevent potential harm from occurring while legal disputes are resolved.