In the case of Andrus, Secretary of the Interior v. Shell Oil Co., et al., 1979, the U.S. Supreme Court ruled that under Section 5(a) of Outer Continental Shelf Lands Act (OCSLA), oil and gas leases did not grant lessees exclusive rights to geological data they submitted to the Secretary as part of their exploration plans. The court held that OCSLA allowed for sharing this information with both state governments and third parties after a certain period had passed from when it was first obtained by leaseholders. This decision overturned an earlier ruling by a federal appeals court which had sided with Shell Oil Company's argument against such sharing on grounds including alleged violation of trade secrets protections.

In the dissenting opinion for Andrus v. Shell Oil Co., Justice Rehnquist disagreed with the majority's interpretation of Section 21 of the Mineral Leasing Act, arguing that it did not give authority to the Secretary of Interior to regulate oil and gas exports. He contended that Congress had intended this power to lie solely within its own purview, as demonstrated by their explicit delegation in other statutes but not in this one. Furthermore, he argued against reading an export control provision into a statute where none existed explicitly. The dissent also pointed out inconsistencies between this decision and previous rulings on similar matters involving statutory construction principles applied by courts when interpreting congressional intent from legislative history or text ambiguity.