Editors' Summary: In 1981, in an effort to gain leverage over federal plans to sell outer continental shelf oil and gas leases, California and several environmental groups sued the Interior Department. They argued that under §307(c)(1) of the Coastal Zone Management Act (CZMA), Interior must certify that such lease sales are consistent with approved state coastal management plans. The case progressed to the Supreme Court, where last January, in Secretary of the Interior v. California, the Court ruled against the plaintiffs. The Court construed the states' power under the CZMA narrowly, casting serious doubt on §307(c)(1)'s application to any activity not physically within the coastal zone. This Comment examines the law at issue in the dispute, the possible consequences of the ruling, and a reaction to the ruling now brewing in Congress.