In the case of Udall, Secretary of the Interior v. Tallman et al., 1964, the Supreme Court ruled in favor of Stewart Udall, then-Secretary of the Interior. The dispute centered around oil and gas leases on public lands in Alaska issued by a previous Secretary under regulations permitting such leases "subject to valid existing rights." When Udall suspended these leases based on his interpretation that they were not subject to any prior rights or claims (a position contrary to that held by his predecessor), lessees sued for breach of contract. They argued that their lease contracts should be interpreted according to what they believed was its plain meaning at issuance time rather than how it was later reinterpreted by another administration official. However, the court upheld Udall's authority as secretary to interpret and apply departmental rules and regulations even if this meant changing an earlier interpretation made under a different secretaryship tenure. It concluded that when there is ambiguity about administrative regulation meanings like here with 'valid existing rights', courts must defer judgment towards those who have expertise - i.e., agency administrators.

In the dissenting opinion for UDALL, SECRETARY OF THE INTERIOR v. TALLMAN et al., Justice Black argued that the majority's decision to uphold executive orders restricting oil and gas drilling on public lands was an overreach of executive power. He contended that Congress had not explicitly granted such authority to the President or his appointees in this area, and thus they should not be allowed to exercise it unilaterally. Furthermore, he expressed concern about potential abuse of this power by future administrations if left unchecked. In essence, Justice Black believed that any restrictions on land use should come directly from legislation passed by Congress rather than through administrative action taken by the Executive Branch.