BP AMERICA PRODUCTION CO., successor in inter- est to AMOCO PRODUCTION CO., et al. v. BURTON, ACTING ASSISTANT SECRETARY, LAND AND MINERALS MANAGEMENT, DEPARTMENT OF THE INTERIOR, et al.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
84 OCTOBER TERM, 2006
Syllabus
BP AMERICA PRODUCTION CO., successor in inter-
est to AMOCO PRODUCTION CO., et al. v. BURTON,
ACTING ASSISTANT SECRETARY, LAND AND
MINERALS MANAGEMENT, DEPARTMENT
OF THE INTERIOR, et al.
certiorari to the united states court of appeals for
the district of columbia circuit
No. 05–669. Argued October 4, 2006—Decided December 11, 2006
After the Interior Department’s Minerals Management Service (MMS) is
sued administrative orders assessing petitioners for royalty underpay
ments on gas leases they held on Government lands, petitioners filed an
administrative appeal, contending, inter alia, that the proceedings were
barred by 28 U. S. C. § 2415(a), which provides in relevant part: “[E]very
action for money damages brought by the United States or an . . .
agency thereof which is founded upon any contract . . . shall be barred
unless the complaint is filed within six years after the right of action
accrues or within one year after final decisions have been rendered in
applicable administrative proceedings.” (Emphasis added.) The As
sistant Secretary of the Interior denied the appeals, ruling that § 2415(a)
did not govern the administrative order. The District Court agreed,
and the Court of Appeals affirmed.
Held: Section 2415(a)’s 6-year statute of limitations applies only to court
actions, not to the administrative payment orders involved in this case.
Pp. 91–101.
(a) Unless otherwise defined, statutory terms are generally inter
preted in accordance with their ordinary meaning. Read in this way,
§ 2415(a)’s text is quite clear: Its key terms—“action” and “complaint”—
are ordinarily used in connection with judicial, not administrative, pro
ceedings. See, e. g., Unexcelled Chemical Corp. v. United States, 345
U. S. 59, 66. The phrase “action for money damages” reinforces this
reading because the term “damages” is generally used to mean pecuni
ary compensation or indemnity recovered in court. Moreover, the fact
that § 2415(a) distinguishes between judicial and administrative proceed
ings by providing that an “action” must commence “within one year
after final decisions have been rendered in applicable administrative
proceedings” shows that Congress knew how to identify administrative
proceedings and manifestly had two separate concepts in mind when it
enacted § 2415(a). Pp. 91–92.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
85 Cite as: 549 U. S. 84 (2006)
Syllabus
(b) Petitioners’ assertion that § 2415(a)’s term “action” is commonly
used to refer to administrative, as well as judicial, proceedings, is not
persuasive. The numerous statutes and regulations cited to document
this supposed usage actually undermine petitioners’ argument, since
none of them uses the term “action” standing alone to refer to adminis
trative proceedings. Rather, each includes a modifier, referring to an
“administrative action,” a “civil or administrative action,” or “adminis
trative enforcement actions.” Section 2415(a)’s references to “every ac
tion for money damages” founded upon “any contract” (emphasis added)
do not assist petitioners, as they do not broaden the ordinary meaning
of the key term “action.” Pennsylvania v. Delaware Valley Citizens’
Council for Clean Air, 478 U. S. 546, and West v. Gibson, 527 U. S. 212,
distinguished. Pp. 92–94.
(c) Petitioners’ suggestion that an MMS payment order constitutes a
“complaint” under § 2415(a) is also rejected. Their examples of statutes
and regulations employing the term “complaint” in the administrative
context are unavailing, since such occasional usage of the term does not
alter its primary meaning, which concerns the initiation of a civil action.
Moreover, an MMS payment order lacks the essential attributes of a
complaint, which is a filing that commences a proceeding that may result
in a legally binding order providing relief. In contrast, an MMS order
in and of itself imposes a legal obligation on the party to which it is
issued. Given that the failure to comply with such an order can result
in fines of up to $10,000 a day, see 30 U. S. C. § 1719(c), the order plays
an entirely different role from that of a “complaint.” P. 95.
(d) Any remaining doubts are erased by the canon that statutes of
limitations are construed narrowly against the government. This
canon is rooted in the traditional rule that time does not run against the
King. A corollary of this rule is that a sovereign that elects to subject
itself to a statute of limitations is given the benefit of the doubt if the
statute’s scope is ambiguous. Bowers v. New York & Albany Lighter
age Co., 273 U. S. 346, distinguished. Pp. 95–96.
(e) The Court disagrees with petitioners’ argument that interpreting
§ 2415(a) as applying only to judicial actions renders § 2415(i)—which
specifies that “[t]he provisions of this section shall not prevent the
United States . . . from collecting any claim . . . by means of administra
tive offset”—superfluous in contravention of the canon against reading
a statute in a way that makes part of it redundant. Under the Court’s
interpretation, § 2415(i) is not mere surplusage, but clarifies that admin
istrative offsets are not covered by § 2415(a) even if they are viewed as
an adjunct of a court action. To accept petitioners’ argument, on the
other hand, the Court would have to hold either that § 2415(a) applied
to administrative actions when it was enacted in 1966 or that it was

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
86 BP AMERICA PRODUCTION CO. v. BURTON
Syllabus
extended to reach administrative actions when § 2415(i) was added in
1982. The clear meaning of § 2415(a)’s text, which has not been
amended, refutes the first of these propositions, and accepting the latter
would require the unrealistic conclusion that in 1982 Congress pro
ceeded to enlarge § 2415 to cover administrative proceedings by the
oblique and cryptic route of inserting text expressly excluding a single
administrative vehicle from the statute’s reach. Pp. 96–99.
(f) Although interpreting § 2415(a) as applying only to judicial actions
may result in certain peculiarities, petitioners’ alternative interpreta
tion would itself result in disharmony. For instance, MMS oil and gas
lease payment orders are now prospectively subject to a 7-year statute
of limitations except with respect to obligations arising out of leases of
Indian land. 30 U. S. C. § 1724(b)(1). Given the exhortation that the
Interior Secretary “aggressively carry out his trust responsibility in the
administration of Indian oil and gas,” § 1701(a)(4), it seems unlikely that
Congress intended to impose a shorter, 6-year statute of limitations for
payment orders regarding Indian lands. Finally, while cogent, petition
ers’ policy arguments as to why limiting § 2415(a) to judicial actions
frustrates the statute’s purposes must be viewed in perspective. For
example, because there are always policy arguments against affording
the sovereign special treatment, the relevant inquiry in a case like this
is simply how far Congress meant to go when it enacted the statute
of limitations in question. Prior to § 2415(a)’s enactment, Government
contract actions were not subject to any statute of limitations. See
Guaranty Trust Co. v. United States, 304 U. S. 126, 132. Absent con
gressional action changing this rule, it remains the law, and § 2415(a)
betrays no intent to change the rule as it applies to administrative pro
ceedings. Pp. 99–101.
410 F. 3d 722, affirmed.
Alito, J., delivered the opinion of the Court, in which all other Members
joined, except Roberts, C. J., and Breyer, J., who took no part in the
consideration or decision of the case.
Jeffrey A. Lamken argued the cause for petitioners.
With him on the briefs was Steven R. Hunsicker.
Daryl Joseffer argued the cause for respondents. With
him on the brief were Solicitor General Clement, Assistant
Attorney General Wooldridge, Deputy Solicitor General

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
87 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
Kneedler, William B. Lazarus, Martin J. Lalonde, and John
A. Bryson.*
Justice Alito delivered the opinion of the Court.
This case presents the question whether administrative
payment orders issued by the Department of the Interior’s
Minerals Management Service (MMS) for the purpose of as
sessing royalty underpayments on oil and gas leases fall
within 28 U. S. C. § 2415(a), which sets out a 6-year statute
of limitations for Government contract actions. We hold
that this provision does not apply to these administrative
payment orders, and we therefore affirm.
I
A
The Mineral Leasing Act of 1920 (MLA) authorizes the
Secretary of the Interior to lease public-domain lands to pri
vate parties for the production of oil and gas. 41 Stat. 437,
as amended, 30 U. S. C. § 181 et seq. MLA lessees are obli
gated to pay a royalty of at least “12.5 percent in amount or
value of the production removed or sold from the lease.”
§ 226(b)(1)(A).
In 1982, Congress enacted the Federal Oil and Gas Roy
alty Management Act (FOGRMA), 96 Stat. 2447, as amended,
30 U. S. C. § 1701 et seq., to address the concern that the
“system of accounting with respect to royalties and other
payments due and owing on oil and gas produced from such
*Briefs of amici curiae urging reversal were filed for the American
Petroleum Institute by Jonathan A. Hunter, Shannon S. Holtzman, and
Harry M. Ng; and for the Mountain States Legal Foundation by William
Perry Pendley.
Jill Elise Grant, Harry R. Sachse, Thomas H. Shipps, Patricia A. Ma
drid, Attorney General of New Mexico, Christopher D. Coppin, Martin
Lobel, and Richard Chivaro filed a brief for the Jicarilla Apache Nation
et al. as amici curiae urging affirmance.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
88 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
lease sites [was] archaic and inadequate.” § 1701(a)(2).
FOGRMA ordered the Secretary of the Interior to “audit
and reconcile, to the extent practicable, all current and past
lease accounts for leases of oil or gas and take appropriate
actions to make additional collections or refunds as war
ranted.” § 1711(c)(1). The Secretary, in turn, has assigned
these duties to MMS. 30 CFR § 201.100 (2006).
Under FOGRMA, lessees are responsible in the first in
stance for the accurate calculation and payment of royal
ties. 30 U. S. C. § 1712(a). MMS, in turn, is authorized to
audit those payments to determine whether a royalty has
been overpaid or underpaid. §§ 1711(a) and (c); 30 CFR
§§ 206.150(c), 206.170(d). In the event that an audit suggests
an underpayment, it is MMS’ 1 practice to send the lessee
a letter inquiring about the perceived deficiency. If, after
reviewing the lessee’s response, MMS concludes that the les
see owes additional royalties, MMS issues an order requiring
payment of the amount due. Failure to comply with such an
order carries a stiff penalty: “Any person who—(1) know
ingly or willfully fails to make any royalty payment by the
date as specified by [an] order . . . shall be liable for a penalty
of up to $10,000 per violation for each day such violation
continues.” 30 U. S. C. § 1719(c). The Attorney General
may enforce these orders in federal court. § 1722(a).
An MMS payment order may be appealed, first to the Di
rector of MMS and then to the Interior Board of Land Ap
peals or to an Assistant Secretary. 30 CFR §§ 290.105,
290.108. While filing an appeal does not generally stay the
payment order, § 218.50(c), MMS will usually suspend the or
der’s effect after the lessee complies with applicable bonding
or financial solvency requirements, § 243.8.
Congress supplemented this scheme by enacting the Fed
eral Oil and Gas Royalty Simplification and Fairness Act of
1996 (FOGRSFA), 110 Stat. 1700, as amended, 30 U. S. C.
1 MMS is not always the auditing body, as MMS may delegate its author
ity to the host State or an Indian tribe. 30 U. S. C. §§ 1732, 1735.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
89 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
§ 1701 et seq. FOGRSFA adopted a prospective 7-year stat
ute of limitations for any “judicial proceeding or demand”
for royalties arising under a federal oil or gas lease.
§ 1724(b)(1). The parties agree that this provision applies
both to judicial actions (“judicial proceeding[s]”) and to MMS’
administrative payment orders (“demand[s]”) arising on or
after September 1, 1996. Ibid. This provision does not,
however, apply to judicial proceedings or demands arising
from leases of Indian land or underpayments of royalties on
pre-September 1, 1996, production. FOGRSFA §§ 9, 11, 110
Stat. 1717, notes following 30 U. S. C. § 1701.
There is no dispute that a lawsuit in court to recover royal
ties owed to the Government on pre-September 1, 1996,
production is covered by 28 U. S. C. § 2415(a), which sets
out a general 6-year statute of limitations for Government
contract actions. That section, which was enacted in 1966,
provides in relevant part:
“Subject to the provisions of section 2416 of this title,
and except as otherwise provided by Congress, every
action for money damages brought by the United States
or an officer or agency thereof which is founded upon
any contract express or implied in law or fact, shall be
barred unless the complaint is filed within six years
after the right of action accrues or within one year after
final decisions have been rendered in applicable adminis
trative proceedings required by contract or by law,
whichever is later.” (Emphasis added.)
Whether this general 6-year statute of limitations also gov
erns MMS administrative payment orders concerning pre-
September 1, 1996, production is the question that we must
decide in this case.
B
Petitioner BP America Production Co. holds gas leases
from the Federal Government for lands in New Mexico’s San
Juan Basin. BP’s predecessor, Amoco Production Co., first

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
90 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
entered into these leases nearly 50 years ago, and these
leases require the payment of the minimum 12.5 percent roy
alty prescribed by 30 U. S. C. § 226(b)(1)(A). For years,
Amoco calculated the royalty as a percentage of the value of
the gas as of the moment it was produced at the well. In
1996, MMS sent lessees a letter directing that royalties
should be calculated based not on the value of the gas at the
well, but on the value of the gas after it was treated to meet
the quality requirements for introduction into the Nation’s
mainline pipelines.2 Consistent with this guidance, MMS in
1997 ordered Amoco to pay additional royalties for the pe
riod from January 1989 through December 1996 in order to
cover the difference between the value of the treated gas
and its lesser value at the well.
Amoco appealed the order, disputing MMS’ interpretation
of its royalty obligations and arguing that the payment order
was in any event barred in part by the 6-year statute of
limitations in 28 U. S. C. § 2415(a). The Assistant Secretary
of the Interior denied the appeal and ruled that the statute
of limitations was inapplicable.
Amoco, together with petitioner Atlantic Richfield Co.,
sought review in the United States District Court for the
District of Columbia, which agreed with the Assistant Secre
tary that § 2415(a) did not govern the administrative order.
Amoco Production Co. v. Baca, 300 F. Supp. 2d 1, 21 (2003).
The Court of Appeals for the District of Columbia Circuit
affirmed, Amoco Production Co. v. Watson, 410 F. 3d 722,
733 (2005), and we granted certiorari, 547 U. S. 1068 (2006),
in order to resolve the conflict between that decision and the
contrary holding of the United States Court of Appeals for
the Tenth Circuit in OXY USA, Inc. v. Babbitt, 268 F. 3d
1001, 1005 (2001) (en banc). We now affirm.
2 MMS intended this letter to implement its regulations, which required
lessees “to place gas in marketable condition at no cost to the Federal
Government unless otherwise provided in the lease agreement.” 30 CFR
§ 206.152(i) (1996).

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
Cite as: 549 U. S. 84 (2006) 91
Opinion of the Court
We start, of course,
II
A
with the statutory text. Central
Bank of Denver, N. A. v. First Interstate Bank of Denver,
N. A., 511 U. S. 164, 173 (1994). Unless otherwise defined,
statutory terms are generally interpreted in accordance with
their ordinary meaning. Perrin v. United States, 444 U. S.
37, 42 (1979). Read in this way, the text of § 2415(a) is
quite clear.
The statute of limitations imposed by § 2415(a) applies
when the Government commences any “action for money
damages” by filing a “complaint” to enforce a contract, and
the statute runs from the point when “the right of action
accrues.” The key terms in this provision—“action” and
“complaint”—are ordinarily used in connection with judicial,
not administrative, proceedings. In 1966, when § 2415(a)
was enacted, a commonly used legal dictionary defined the
term “right of action” as “[t]he right to bring suit; a legal
right to maintain an action,” with “suit” meaning “any pro
ceeding . . . in a court of justice.” Black’s Law Dictionary
1488, 1603 (4th ed. 1951) (hereinafter Black’s). Likewise,
“complaint” was defined as “the first or initiatory pleading
on the part of the plaintiff in a civil action.” 3 Id., at 356.
See also Unexcelled Chemical Corp. v. United States, 345
U. S. 59, 66 (1953) (holding that filing a complaint, in the ordi
nary sense of the term, means filing a suit in court, not ini
tiating an administrative proceeding: “Commencement of
an action by the filing of a complaint has too familiar a his
tory . . . for us to assume that Congress did not mean to use
the words in their ordinary sense”). The phrase “action for
3 These primary definitions have not changed in substance since 1966.
Black’s (8th ed. 2004) now defines “action” as “[a] civil or criminal judicial
proceeding” and a “complaint” as “[t]he initial pleading that starts a civil
action and states the basis for the court’s jurisdiction, the basis for the
plaintiff ’s claim, and the demand for relief.” Id., at 31, 303.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
92 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
money damages” reinforces this reading because the term
“damages” is generally used to mean “pecuniary compensa
tion or indemnity, which may be recovered in the courts.”
Black’s 466 (emphasis added).
Nothing in the language of § 2415(a) suggests that Con
gress intended these terms to apply more broadly to admin
istrative proceedings. On the contrary, § 2415(a) distin
guishes between judicial and administrative proceedings.
Section 2415(a) provides that an “action” must commence
“within one year after final decisions have been rendered
in applicable administrative proceedings.” Thus, Congress
knew how to identify administrative proceedings and mani
festly had two separate concepts in mind when it enacted
§ 2415(a).4
B
In an effort to show that the term “action” is commonly
used to refer to administrative, as well as judicial, proceed
ings, petitioners have cited numerous statutes and regula
tions that, petitioners claim, document this usage.5 These
4 Moreover, it seems unlikely that Congress intended administrative pro
ceedings to commence within one year after the conclusion of administra
tive proceedings.
5 See, e. g., 42 U. S. C. § 5205(a)(1) (statute of limitations for “administra
tive action[s] to recover any payment[s] made to a State or local govern
ment for disaster or emergency assistance”); 12 U. S. C. § 1441a(b)(11)(G)
(requiring Resolution Trust Corporation to maintain staff to assist with
certain “cases, civil claims, and administrative enforcement actions”); 15
U. S. C. § 78u(h)(9)(B) (Securities Exchange Act of 1934 provision noting
that certain “[f]inancial records . . . may be disclosed or used only in an
administrative, civil, or criminal action”). See also 7 CFR § 3018.400(c)
(2006) (Department of Agriculture regulation regarding “administrative
action[s] for the imposition of a civil penalty” for failure to file disclosure
forms); 71 Fed. Reg. 7407 (2006) (to be codified in 12 CFR § 1412.2(l)(1))
(Farm Credit System Insurance Corporation regulation defining “prohib
ited indemnification payment” to include reimbursement for a civil money
penalty of judgment resulting from any “administrative or civil action”
instituted by the Farm Credit Administration); 10 CFR pt. 820, App. A,

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
93 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
examples, however, actually undermine petitioners’ argu
ment, since none of them uses the term “action” standing
alone to refer to administrative proceedings. Rather, each
example includes a modifier of some sort, referring to an
“administrative action,” a “civil or administrative action,”
or “administrative enforcement actions.” This pattern of
usage buttresses the point that the term “action,” standing
alone, ordinarily refers to a judicial proceeding.
Petitioners contend that their broader interpretation of
the statutory term “action” is supported by the reference
to “every action for money damages” founded upon “any
contract.” 28 U. S. C. § 2415(a) (emphasis added). But the
broad terms “every” and “any” do not assist petitioners, as
they do not broaden the ordinary meaning of the key term
“action.”
Petitioners argue that their interpretation is supported by
Pennsylvania v. Delaware Valley Citizens’ Council for
Clean Air, 478 U. S. 546 (1986), and West v. Gibson, 527 U. S.
212 (1999), but this reliance is misplaced. In Delaware Val
ley Citizens’ Council, we construed the attorney’s fee provi
sion of the Clean Water Act (CWA), which authorizes a
“court, in issuing any final order in any action brought pursu
ant to subsection (a) of this section, [to] award costs of litiga
tion . . . to any party.” 42 U. S. C. § 7604(d). We permitted
the recovery of fees both for work done in court and in subse
quent administrative proceedings. But the pertinent statu
tory provision in that case did not employ the key terms that
appear in the statute at issue here. Specifically, the CWA
provision referred to “litigation,” not to an “action” com
menced by the filing of a “complaint.” Moreover, “the work
done by counsel [in the administrative phase of the case] was
IX–b (2006) (“Administrative actions, such as determination of award fees
where [Department of Energy] contracts provide for such determinations,
will be considered separately from any civil penalties that may be imposed
under this Enforcement Policy”).

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
94 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
as necessary to the attainment of adequate relief . . . as was
all of their earlier work in the courtroom . . . obtaining the
consent decree.” 478 U. S., at 558. And we expressly re
served judgment on the question “whether an award of at
torney’s fees is appropriate . . . when there is no connected
court action in which fees are recoverable.” Id., at 560, n. 5.
West helps petitioners even less. There, we considered
whether the Equal Employment Opportunity Commission
(EEOC) could order a federal agency to pay compensatory
damages in an administrative proceeding. Section 717(b) of
Title VII of the Civil Rights Act of 1964, 42 U. S. C. § 2000e–
16(b), authorized the EEOC to employ “appropriate reme
dies,” but did not specifically authorize damages, and § 717(c)
authorized a subsequent court action against an employer
agency, 42 U. S. C. § 2000e–16(c). In 1991, Congress added
Rev. Stat. § 1977A(a)(1), 42 U. S. C. § 1981a(a)(1), which pro
vided that “[i]n an action brought by a complaining party
under section 706 or 717 . . . the complaining party may re
cover compensatory . . . damages.” In West, the respondent
employee argued that the enactment of § 1981a(a)(1) showed
that Congress did not consider compensatory damages to be
“appropriate remedies” in an EEOC proceeding, as opposed
to an action brought by an aggrieved employee. If Congress
had wished to authorize the award of compensatory damages
in an EEOC proceeding, the respondent employee reasoned,
Congress would have so provided in § 1981a(a)(l), by ex
pressly cross-referencing § 717(c). We rejected this argu
ment, but in doing so we did not hold that an EEOC proceed
ing is an “action” under § 1981a(a)(1). Rather, we simply
concluded that the EEOC’s authorization under § 717(b) to
award “appropriate remedies” was broad enough to encom
pass compensatory damages. 527 U. S., at 220–221.
For these reasons, we are not persuaded by petitioners’
argument that the term “action” in § 2415(a) applies to the
administrative proceedings that follow the issuance of an
MMS payment order.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
95 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
C
We similarly reject petitioners’ suggestion that an MMS
letter or payment order constitutes a “complaint” within the
meaning of § 2415(a). Petitioners point to examples of stat
utes and regulations that employ the term “complaint” in the
administrative context. See, e. g., 15 U. S. C. § 45(b) (requir
ing the Federal Trade Commission to serve a “complaint” on
a party suspected of engaging in an unfair method of compe
tition); 29 CFR § 102.15 (2006) (a “complaint” initiates unfair
labor practice proceedings before the National Labor Rela
tions Board). But the occasional use of the term to describe
certain administrative filings does not alter its primary
meaning, which concerns the initiation of “a civil action.”
Black’s 356. Moreover, even if the distinction between ad
ministrative and judicial proceedings is put aside, an MMS
payment order lacks the essential attributes of a complaint.
While a complaint is a filing that commences a proceeding
that may in the end result in a legally binding order provid
ing relief, an MMS payment order in and of itself imposes a
legal obligation on the party to which it is issued. As noted,
the failure to comply with such an order can result in fines
of up to $10,000 a day. An MMS payment order, therefore,
plays an entirely different role from that of a “complaint.” 6
D
To the extent that any doubts remain regarding the mean
ing of § 2415(a), they are erased by the rule that statutes of
limitations are construed narrowly against the government.
E. I. DuPont de Nemours & Co. v. Davis, 264 U. S. 456 (1924).
6 There was some question at oral argument whether MMS’ initial letter
might constitute a “complaint” within the meaning of § 2415(a). Petition
ers did not advance this argument, and recognized at oral argument that
neither the statute nor the regulations require the issuance of such a let
ter. Tr. of Oral Arg. 7–9. The Government, for its part, observed that
all such a letter does is request information, as the agency has not yet
decided whether to assert a claim. Id., at 28. This is not a complaint.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
96 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
This canon is rooted in the traditional rule quod nullum tem
pus occurrit regi—time does not run against the King.
Guaranty Trust Co. v. United States, 304 U. S. 126, 132
(1938). A corollary of this rule is that when the sovereign
elects to subject itself to a statute of limitations, the sover
eign is given the benefit of the doubt if the scope of the stat
ute is ambiguous.
Bowers v. New York & Albany Lighterage Co., 273 U. S.
346 (1927), cited by petitioners, is not to the contrary.
There, as here, the issue was the scope of a statute of limita
tions. The provision in that case, however, provided that
“ ‘[n]o suit or proceeding for the collection of any such taxes’ ”
shall commence more than five years after the filing of the
return. Id., at 348–349. The Government argued that the
terms “proceeding” and “suit” were coterminous, and urged
further that any ambiguity should be resolved in its favor.
The Court recognized the canon, restating it much as we
have above. Id., at 349. But the Court concluded that the
canon had no application in that case because the text of the
relevant statute, unlike § 2415(a), applied clearly and sepa
rately to “suits” and “proceedings,” and the Court saw no
reason to give these different terms the same meaning. Id.,
at 349–350.
E
We come now to petitioners’ argument that interpreting
§ 2415(a) as applying only to judicial actions would render
subsection (i) of the same statute superfluous. Subsection
(i) provides as follows:
“The provisions of this section shall not prevent the
United States or an officer or agency thereof from col
lecting any claim of the United States by means of ad
ministrative offset, in accordance with section 3716 of
title 31.” 28 U. S. C. § 2415(i).
An administrative offset is a mechanism by which the Gov
ernment withholds payment of a debt that it owes another

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
Cite as: 549 U. S. 84 (2006) 97
Opinion of the Court
party in order to recoup a payment that this party owes the
Government. 31 U. S. C. § 3701(a)(1). Thus, under subsec
tion (i), the Government may recover a debt via an adminis
trative offset even if the Government would be time barred
under subsection (a) from pursuing the debt in court.
Petitioners argue that, if § 2415(a) applies only to judicial
proceedings and not to administrative proceedings, there is
no need for § 2415(i)’s rule protecting a particular adminis
trative mechanism (i. e., an administrative offset) from the
statute of limitations set out in subsection (a). Invoking the
canon against reading a statute in a way that makes part
of the statute redundant, see, e. g., TRW Inc. v. Andrews,
534 U. S. 19, 31 (2001), petitioners contend that subsection
(i) shows that subsection (a) was meant to apply to adminis
trative, as well as judicial, proceedings. We disagree.
As the Court of Appeals noted, subsection (i) was not
enacted at the same time as subsection (a) but rather was
added 16 years later by the Debt Collection Act of 1982. 96
Stat. 1749. This enactment followed a dispute between the
Office of the Comptroller General of the United States, head
of the agency then named the General Accounting Office
(GAO), and the Department of Justice’s Office of Legal Coun
sel (OLC) over whether an administrative offset could be
used to recoup a debt where a judicial recoupment action
was already time barred.
In 1978, in response to a question from the United States
Civil Service Commission, OLC opined that an administra
tive offset could not be used to recoup a debt as to which a
judicial action was already time barred. OLC reached this
conclusion not because it believed that § 2415(a) reached ad
ministrative proceedings generally,7 but rather because of
the particular purpose of an administrative offset. “Where
7 Indeed, what emerges strikingly from OLC’s 1978 opinion is that no
one at the time—neither OLC nor GAO—even contemplated that § 2415(a)
applied to administrative procedures in the first instance. Nor have peti
tioners pointed to any source demonstrating otherwise.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
98 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
[a] debt has not been reduced to judgment,” OLC stated, “an
administrative offset is merely a pre-judgment attachment
device.” Memorandum from John M. Harmon, Assistant At
torney General, OLC, to Alan K. Campbell, Chairman, U. S.
Civil Service Commission Re: Effect of Statute of Limita
tions on Administrative Collection of United States Claims 3
(Sept. 29, 1978), Joint Lodging. OLC opined that a prejudg
ment attachment device such as this exists only to preserve
funds to satisfy any judgment the creditor subsequently ob
tains. Id., at 4 (citing cases). OLC therefore concluded
that, where a lawsuit is already foreclosed by § 2415(a), an
administrative offset that is the functional equivalent of a
pretrial attachment is also unavailable. Id., at 3.
GAO disagreed. See In re Collection of Debts—Statute
of Limitations on Administrative Setoff, 58 Comp. Gen. 501,
504–505 (1979). In its view, the question was answered by
“[t]he general rule . . . that statutes of limitations appli
cable to suits for debts or money demands bar or run
only against the remedy (the right to bring suit) to
which they apply and do not discharge the debt or extin
guish, or even impair, the right or obligation, either in
law or in fact, and the creditor may avail himself of
every other lawful means of realizing on the debt or obli
gation. See Mascot Oil Co. v. United States, 42 F. 2d
309 (Ct. Cl. 1930), affirmed 282 U. S. 434; and 33 Comp.
Gen. 66 (1953). See also Ready-Mix Concrete Co. v.
United States, 130 F. Supp. 390 (Ct. Cl. 1955).” Ibid.
That Congress had time barred the judicial remedy, GAO
reasoned, imposed no limit on the administrative remedy.
The OLC–GAO dispute reveals that, even under the inter
pretation of subsection (a)—the one we are adopting—that
considers it applicable only to court proceedings, subsection
(i) is not mere surplusage. It clarifies that administrative
offsets are not covered by subsection (a) even if they are
viewed as an adjunct of a court action.

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
99 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
To accept petitioners’ argument, on the other hand, we
would have to hold either that § 2415(a) applied to adminis
trative actions when it was enacted in 1966 or that it was
extended to reach administrative actions when subsection
(i) was added in 1982. The clear meaning of the text of
§ 2415(a), which has not been amended, refutes the first of
these propositions, and accepting the latter would require us
to conclude that in 1982 Congress elected to enlarge § 2415 to
cover administrative proceedings by inserting text expressly
excluding a single administrative vehicle from the statute’s
reach. It is entirely unrealistic to suggest that Congress
would proceed by such an oblique and cryptic route.
III
Petitioners contend that interpreting § 2415(a) as applying
only to judicial actions results in a statutory scheme with
peculiarities that Congress could not have intended. For
example, petitioners note that while they are required by
statute to preserve their records regarding royalty obliga
tions for only seven years, 30 U. S. C. § 1724(f), the interpre
tation of § 2415(a) adopted by the Court of Appeals permits
MMS to issue payment orders that reach back much further.
We are mindful of the fact that a statute should be read
where possible as effecting a “ ‘symmetrical and coherent
regulatory scheme,’ ” FDA v. Brown & Williamson Tobacco
Corp., 529 U. S. 120, 133 (2000), but here petitioners’ alter
native interpretation of § 2415(a) would itself result in dis
harmony. For instance, under FOGRSFA, MMS payment
orders regarding oil and gas leases are now prospectively
subject to a 7-year statute of limitations except with respect
to obligations arising out of leases of Indian land. Conse
quently, if we agreed with petitioners that § 2415(a) applies
generally to administrative proceedings, payment orders re
lating to oil and gas royalties owed under leases of Indian
land would be subject to a shorter (i. e., 6-year) statute of
limitations than similar payment orders relating to leases of

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
100 BP AMERICA PRODUCTION CO. v. BURTON
Opinion of the Court
other public-domain lands (which would be governed by
FOGRSFA’s new 7-year statute). Particularly in light of
Congress’ exhortation that the Secretary of the Interior “ag
gressively carry out his trust responsibility in the adminis
tration of Indian oil and gas,” 30 U. S. C. § 1701(a)(4), it seems
unlikely that Congress intended to impose a shorter statute
of limitations for payment orders regarding Indian lands.
Petitioners contend, finally, that interpreting § 2415(a) as
applying only to judicial actions would frustrate the statute’s
purposes of providing repose, ensuring that actions are
brought while evidence is fresh, lightening recordkeeping
burdens, and pressuring federal agencies to assert federal
rights promptly. These are certainly cogent policy argu
ments, but they must be viewed in perspective.
For one thing, petitioners overstate the scope of the prob
lem, since Congress of course can enact and has enacted spe
cific statutes of limitations to govern specific administrative
actions. See, e. g., 42 U. S. C. § 5205(a)(1) (statute of limita
tions for an administrative action to recover payments made
to state governments for disaster or emergency assistance).
Indeed, in 1996, FOGRSFA imposed just such a limitation
prospectively on all non-Indian land, oil, and gas lease claims.
Second, and more fundamentally, the consequences of in
terpreting § 2415(a) as limited to court actions must be con
sidered in light of the traditional rule exempting proceedings
brought by the sovereign from any time bar. There are al
ways policy arguments against affording the sovereign this
special treatment, and therefore in a case like this, where
the issue is how far Congress meant to go when it enacted a
statute of limitations applicable to the Government, arguing
that an expansive interpretation would serve the general
purposes of statutes of limitations is somewhat beside the
point. The relevant inquiry, instead, is simply how far Con
gress meant to go when it enacted the statute of limitations
in question. Here prior to the enactment of § 2415(a) in
1966, contract actions brought by the Government were not

549US1 Unit: $$U6 [04-23-08 16:36:49] PAGES PGT: OPIN
101 Cite as: 549 U. S. 84 (2006)
Opinion of the Court
subject to any statute of limitations. See Guaranty Trust
Co., 304 U. S., at 132. Absent congressional action changing
this rule, it remains the law, and the text of § 2415(a) betrays
no intent to change this rule as it applies to administrative
proceedings.
In the final analysis, while we appreciate petitioners’ argu
ments, they are insufficient to overcome the plain meaning
of the statutory text. We therefore hold that the 6-year
statute of limitations in § 2415(a) applies only to court actions
and not to the administrative proceedings involved in this
case.
* * *
For these reasons, the judgment of the Court of Appeals
for the District of Columbia Circuit is affirmed.
It is so ordered.
The Chief Justice and Justice Breyer took no part in
the consideration or decision of this case.