In Fletcher v. United States, the Tenth Circuit (in an opinion by Judge Paul Kelly) rejected claims by members of the Osage Tribe of Oklahoma that the district court improperly limited the government’s obligation to perform an accounting of revenues derived from the mineral estate beneath their former reservation.

The tribal members wanted a more detailed accounting stretching back to 1906, but the the Tenth Circuit said that trial court properly exercised its discretion to order a more limited accounting. In a 2013 opinion in this case, the Tenth Circuit said that the required accounting should not be a “green eye-shade death march through every line of every account over the last one hundred years.” (Unsurprisingly, this colorful language was written by now-Justice Neil Gorsuch).