The U.S. Supreme Court case Amoco Production Company v. Southern Ute Indian Tribe et al., 1998, revolved around the ownership of coalbed methane gas (CBM) in a reservation granted to the Southern Ute Indian Tribe by an 1874 treaty and subsequent Acts of Congress. The dispute arose when Amoco began extracting CBM from coal seams under lands where it held leases for oil and gas exploration but did not have explicit rights to CBM extraction. The tribe sued, claiming that they owned the CBM as part of their subsurface mineral estate because it was not specifically addressed in any lease or act transferring rights away from them. The court ruled in favor of Amoco, stating that under federal common law, unless explicitly stated otherwise, all valuable substances - including gases such as CBM - are included within a grant or reservation of "coal." Therefore, since previous acts had transferred "coal" rights to non-tribal entities without specifying exclusion of associated gases like CBM; those parties retained legal right over these resources.

In the dissenting opinion for Amoco Production Company v. Southern Ute Indian Tribe, Justice Ginsburg disagreed with the majority's interpretation of coal as not including coalbed methane gas under the 1909 and 1910 Coal Lands Acts. She argued that this interpretation was inconsistent with Congress' intent at that time to reserve all valuable fuel resources on public lands for federal control and disposal. Furthermore, she contended that it contradicted a previous Supreme Court ruling which held that "coal" included all constituent elements valuable for their heat-producing qualities, such as gases like methane. Lastly, she pointed out inconsistencies in how different courts have interpreted similar statutory language regarding mineral rights reservations in land grants by noting cases where oil and natural gas were considered part of reserved 'oil deposits'. Thus, Justice Ginsburg concluded that given these considerations along with deference to agency expertise (in this case Bureau of Land Management), "coal" should be understood to include coalbed methane gas.