In the case of Wallis v. Pan American Petroleum Corp., 1965, the U.S Supreme Court ruled in favor of Pan American Petroleum Corporation and upheld its right to a natural gas reserve under federal lands in Wyoming. The dispute arose when Wallis, who held leases on adjacent land, claimed that he had rights to the same gas field as it extended into his property. He argued that since Pan American's lease was issued by an administrative agency (the Bureau of Land Management) rather than Congress directly, it did not have exclusive rights to extract from common pools of oil or gas which extend beyond their leased area. However, the court disagreed with this interpretation and stated that such leases granted by government agencies are valid and provide exclusive extraction rights for lessees within their designated areas even if they cover common reservoirs extending into neighboring properties.

In the dissenting opinion for Wallis v. Pan American Petroleum Corp., Justice Black argued that the majority's decision to allow a private party to sue another under an implied right of action from federal regulations was inconsistent with previous court rulings and Congressional intent. He contended that Congress had not explicitly provided this right in its legislation, nor did it intend for courts to infer such rights. Furthermore, he expressed concern about the potential implications of allowing such suits, including opening up floodgates of litigation and potentially undermining regulatory agencies' enforcement efforts by encouraging private parties to take matters into their own hands instead of relying on these agencies. Therefore, he believed that only those who suffered direct harm should be able to bring lawsuits against violators.