In the case of National Independent Coal Operators' Association et al. v. Kleppe, Secretary of the Interior, et al., 1975, coal operators challenged regulations issued by the Department of Interior under authority granted by Federal Coal Leasing Amendments Act (FCLAA) of 1975. The FCLAA required that all federal coal leases be obtained through competitive bidding and set minimum standards for environmental protection in mining operations on leased lands. The plaintiffs argued that these regulations exceeded statutory authority and violated their constitutional rights to due process and equal protection under law. The Supreme Court upheld most aspects of the regulations but invalidated a few provisions as exceeding statutory authority or violating procedural requirements for rulemaking under Administrative Procedure Act (APA). Specifically, it struck down rules requiring lessees to submit detailed plans for mine development before lease issuance; limiting amount of land any one entity could lease; prohibiting leasing to entities not involved in energy production; and imposing additional financial obligations on lessees beyond those specified in statute. However, court rejected claims that act itself was unconstitutional or that its implementation violated due process or equal protection principles. It held that Congress had broad power to regulate use and disposal of public resources like coal deposits on federal lands.

In the dissenting opinion for National Independent Coal Operators' Association et al. v. Kleppe, Secretary of the Interior, et al., Justice William Rehnquist disagreed with the majority's interpretation of Congress's intent in passing the Federal Coal Leasing Amendments Act of 1975. He argued that while Congress intended to prevent large coal companies from monopolizing federal coal leases, it did not intend to completely bar these companies from obtaining any new leases at all. The majority’s ruling effectively barred such companies from securing new leases even if they had disposed of their old ones and were no longer a threat to competition in the industry. Rehnquist believed this was an overly broad interpretation that went beyond what Congress intended and unfairly penalized larger operators who might otherwise be able to contribute positively to national energy production goals.