Los Angeles Farming & Milling Co. v. City of Los Angeles

Background

The city of Los Angeles sued a landowning company called the Los Angeles Farming and Milling Company to quiet the title to use the waters of the Los Angeles River. The Milling Company owns about 10,000 acres roughly ten miles upstream. Both sides trace their claims back to Spanish and Mexican times and to patents later issued by the United States after reviews under an 1851 law. The city says it inherited a paramount pueblo right to take water for the town. The company says its confirmed rancho patent gives riparian rights to the river and its waters.

Reasoning

The California trial court and Supreme Court ruled the city had the older pueblo water right under Spanish and Mexican law, as confirmed in earlier proceedings. The state courts treated patents issued under the 1851 statute as confirmatory rather than as creating new federal rights. The U.S. Supreme Court reviewed those rulings and prior cases and concluded the dispute turns on local law about riparian rights and confirmed grants. Because the matter did not rest on a federal treaty or statute that creates a federal right, the Supreme Court held it lacked authority to review the state judgment.

Real world impact

The state court’s judgment upholding the city’s claimed water use stays in effect because the Supreme Court dismissed the landowner’s writ of error for want of jurisdiction. The High Court did not decide the merits of who ultimately owns the water. Future disputes over riparian water rights tied to Spanish or Mexican grants will be decided under local law unless a clear federal right is presented.