On September 4, 2015, the US Court of Appeals for the Fifth Circuit reversed convictions of CITGO Petroleum Corporation and CITGO Refining and Chemical Company, L.P. (collectively "Citgo"), and in so doing placed potentially significant limits on the scope of strict criminal liability under the Migratory Bird Treaty Act (MBTA) for unintended or indirect killing of migratory birds, a significant issue for energy extraction and production businesses. The case also illuminated a circuit split regarding application of the MBTA.