Rosario C. Doriott Dominguez Denver

Education

• J.D., University of Southern California, Gould School of Law, Los Angeles
• B.A., Psychology, Yale University, New Haven

Professional Experience

Current

• Partner, Ryan Law Firm
  • Rosario focuses her practice on litigation and transactional work encompassing federal, Indian, state, and private oil and gas royalty issues, regularly advising companies in connection with the calculation, payment, and reporting of onshore and offshore, oil and gas royalties.
  • Rosario routinely assists companies in reviewing royalty calculations and payments and unbundling third-party fees to claim transportation and processing allowances in compliance with marketable condition requirements.
  • Rosario routinely assists and defends companies responding to data mining requests, compliance reviews, audits, and other similar investigations conducted by the Office of Natural Resources Revenue (ONRR), Office of Inspector General, and Department of Justice.
  • Rosario frequently defends and represents companies disputing Orders to Report and Pay, Orders to Perform Restructured Accounting, and Denials of Refund Requests issued by ONRR (including its delegated State and Indian Tribal partners). Rosario has appeared in numerous cases before the Director of ONRR, the Director of the Bureau of Indian Affairs, the Interior Board of Land Appeals, and in the 5^th, 10^th, and D.C. Circuits.
  • Rosario’s most recent notable experience includes:
    • IBLA-2020-398, IBLA-2021-176, IBLA-2022-69, Interior Board of Land Appeals, Orders (2023) (finding Appellants produced sufficient evidence to suggest ONRR acted in bad faith during the decision-making process and in compiling the record).
    • Devon Energy Prod. Co., L.P. v. Gould, 421 F.Supp.3d 1213 (D.Wyo. 2019) (vacating Director of ONRR decision assessing additional royalties and alleging improper transportation deductions under marketable condition rule; first federal court decision holding ONRR Director decision improperly expanded upon underlying order to report and pay and agency failed to properly issue underlying order specifying claims);
    • Continental Resources, Inc. v. Gould, 410 F.Supp.3d 30 (D.D.C. 2019) (setting aside Director of ONRR decision assessing additional royalties and alleging improper valuation; first case holding valuation of unprocessed gas sold at wellhead under percentage-of-proceed contracts as processed gas using residue gas pricing was arbitrary, capricious, plainly erroneous, and inconsistent with regulation);
    • Continental Resources, Inc. v. Jewell, 846 F.3d 1232 (D.C. Cir. 2017) (successful case of first impression, determining proper application of the 180-day and 33-month periods for judicial review under 30 U.S.C. § 1724 and reversing lower court ruling determining a lessee’s suit to challenge federal royalty demand was time-barred).

Previous

• Associate, Baker & Hostetler LLP
• Associate, Fulbright & Jaworski LLP (Norton Rose Fulbright)