Energy Consumers & Producers Ass'n v. Department of Energy

How later courts describe this case

• imposing Rule 37 sanctions for failure to obey court order to answer interrogatories truthfully
• the court found an implicit condition in any order to answer interrogatories is that the answer be true, responsive and complete
• conclusory allegations by agency of impairment to obtain similar information in future — not “plausibly supported in some detail” — are insufficient
• agency determination of which oil wells are exempted from reach of relevant statute and regulations is an “in terpretative” rule
• Ohio v. Arthur Andersen noted as being contrary to court's decision
• sanctioned party requested appellate court to vacate district court's sanction order for lying in interrogatory answers, and court of appeals refused where determining truth or falsity of answers would require it to evaluate the merits of the underlying action