Ramapo Water Co. v. City of New York

Background

A private water company incorporated in 1887 to store and supply water filed maps and spent money acquiring options and surveys for lands in the Esopus, Catskill, Schoharie, and Rondout watersheds—about a thousand square miles. The company says a 1895 law let it claim routes and land by filing maps, and it offered to sell water to New York City in 1898. The 1895 law was later repealed, and by 1905 the City was authorized to acquire new water supplies and had already spent large sums on its project.

Reasoning

The key question was whether the company’s filings and earlier statutes gave it a protected, exclusive right that the State could not undo. The Court found no substantial constitutional question. It said the State could repeal the charter, and that filing broad watershed maps—without notice to landowners and without a specific route—did not create an unlimited, vested right to exclude others. The opinion relied on prior New York and Supreme Court decisions holding that map filing alone does not bind the State.

Real world impact

The result lets New York City continue its water project and prevents the company from stopping it by claiming exclusive control over wide watershed areas. Corporations cannot rely on filing sweeping maps to lock up land without giving required notice and showing a specific route or need. The decree dismissing the company’s bill was affirmed, leaving the City’s project free to proceed under state authority.