Texas v. New Mexico
Headline: Court blocks giving a federal tie-breaking vote in the Pecos River Compact dispute, upholds the compact’s terms, and sends unresolved questions about New Mexico’s deliveries back to the Special Master.
Holding: The Court sustained New Mexico’s and the United States’ exceptions to the Special Master, refused to add a federal tie-breaking vote or impose Texas’ measurement method, and returned remaining compliance questions to the Special Master.
- Prevents adding a federal tie-breaker vote to the Pecos River Commission.
- Sends remaining factual disputes about New Mexico’s water deliveries back to the Special Master.
- Keeps the compact’s inflow-outflow method, blocking Texas’ simplified measurement method.
Summary
Background
Texas, New Mexico, and the United States have long disputed how much water should flow from New Mexico into Texas under the Pecos River Compact. The Compact relied on a 1947 engineering study and an inflow-outflow manual to measure how much water Texas could expect. Differences in later studies, measurement methods, and declining flows led Texas to sue, the court appointed a Special Master, and the Pecos River Commission deadlocked because the two state commissioners could not agree.
Reasoning
The Court considered whether it could order a change to the Compact that would give the United States or a third party a vote on the Commission to break ties, and whether it could impose Texas’ simpler measurement method. The Court said no: once Congress approved the Compact it became federal law and the Court cannot rewrite its terms. Article V(a) of the Compact bars the United States Commissioner from voting, so the Court sustained exceptions by New Mexico and the United States to the Special Master’s tie-breaker recommendation. The Court also refused to impose Texas’ “Double Mass Analysis” because the Commission had not adopted it.
Real world impact
The Court sent the case back to the Special Master to finish deciding whether New Mexico actually violated the Compact under the proper inflow-outflow measures. That means the factual questions about which inflows to count and how shortfalls arose will be resolved by further proceedings, not by the Justices changing the Compact’s structure. The opinion encourages the States to negotiate amendments if they want a different decision process.
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