United States v. Gerlach Live Stock Co.

Background

A group of farmers and ranchers owned low-lying lands along the San Joaquin River that were soaked each year by predictable seasonal overflow. The United States built Friant Dam as part of the Central Valley Project, diverting San Joaquin water for irrigation, power, and redistribution, which largely ended the natural inundation those landowners relied on.

Reasoning

The Court examined whether Friant was a navigation project or a reclamation project and concluded Congress had treated it as a reclamation undertaking governed by the Reclamation Act. Because the federal program expressly directed compliance with state water laws, the Court applied California law to decide whether the landowners had compensable rights. Relying on California precedents and the 1928 state constitutional amendment, the Court found the claimants had a compensable right to the seasonal inundation and affirmed awards for compensation. The majority also accepted the date of first substantial impoundment for accrual of interest, as reflected in administrative contracts.

Real world impact

The ruling means federal reclamation projects that stop naturally recurring river flooding may require payment to local landowners when state law recognizes those benefits. It also endorses the practice that federal reclamation authorities should respect and, where necessary, buy or condemn state-created water rights as part of project planning. The decision leaves open some administrative details, like exact deed reservations and interest questions, for later resolution.

Dissents or concurrances

A separate opinion argued that no constitutional property right exists in navigable waters and that statutory purchase authority, not a constitutional rule, supports payment; that opinion also objected to allowing interest.