United States v. Arizona
Headline: Federal plan to build Parker Dam is denied as the Court dismisses the United States’ suit, finding the dam lacked required congressional and presidential approvals and cannot proceed against state opposition.
Holding:
- Blocks federal construction of Parker Dam without explicit congressional and presidential approval.
- Allows Arizona to oppose or stop dam construction absent required federal approvals.
- Affirms river projects need formal engineer surveys and congressional or presidential adoption before work.
Summary
Background
The United States, acting through the Secretary of the Interior and the Federal Emergency Administrator of Public Works, began building Parker Dam on the Colorado River, which forms part of the Arizona–California boundary. The Government contracted with the Metropolitan Water District of Southern California to pay for the dam and planned to use it for power, irrigation, and river regulation. Arizona owns the riverbed east of the stream’s thread, objected, and threatened to stop construction, so the United States sued to enjoin Arizona from interfering.
Reasoning
The central question was whether the United States had the legal authorizations needed to build the dam and to get a court order against Arizona. The Court examined several laws the Government relied on and found them insufficient. An 1899 law requires congressional consent for dams on navigable waters, and the Reclamation Act and its § 25 did not supply that consent for this dam. The Boulder Canyon Project Act did not authorize Parker Dam, and the project had not been approved by the President as required by reclamation statutes. The Court also held that the National Industrial Recovery Act and agency actions did not substitute for the formal congressional or presidential approvals or for the engineer surveys and recommendations Congress requires for river works.
Real world impact
Because the complaint did not show required statutory authorizations, the Court dismissed the suit and declined to enjoin Arizona. As a result, federal officers may not proceed over the State’s objection until the specific legislative and executive approvals and the formal engineering procedures Congress requires are obtained. This leaves control of immediate construction contested and dependent on compliance with those legal steps.
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