Andrus v. Charlestone Stone Products Co.

Background

A company bought 23 federal mining claims near Las Vegas and in 1962 discovered water on one claim used to wash sand and gravel. The Interior Department sought to invalidate many claims because the sand and gravel were later declared "common varieties" that cannot support mining claims. The District Court allowed access to the water; the Ninth Circuit went further and held the water claim itself valid, prompting the Government to appeal to this Court.

Reasoning

The central question was whether water counts as a "valuable mineral" that can form the basis of a federal mining claim under the 1872 law. The Court assumed water could be valuable but looked at the statute’s text, history, and earlier laws (1866 and 1870) that left water rights to local rules. It noted consistent administrative practice against treating water as a locatable mineral and stressed that allowing water claims would clash with Western state water doctrines and cause practical problems. For those reasons, the Court held Congress did not intend water to be a locatable mineral and reversed the court below.

Real world impact

The decision prevents miners from converting wells into exclusive federal mining titles for water and protects existing state-based water appropriation rules. It preserves prior water users’ rights and guides federal agencies and lower courts to treat water claims under local and state law rather than under the federal mining-claim scheme.