California v. Deseret Water, Oil & Irrigation Co.
Headline: Court reverses state decision, holding federal law lets a State waive school-section rights inside later federal forest reservations and select replacement lands, affecting ownership and condemnation of those sections.
Holding: The Court ruled that under a federal law (Section 2275), a State may waive its right to a surveyed school section later included in a forest reservation and select other public lands instead.
- Allows States to exchange school sections inside federal forest reserves for other public lands.
- Parcels surrendered to federal control may be protected from private condemnation.
- Reinforces reliance on Interior Department land-selection practices long used by States.
Summary
Background
A private water and irrigation company sued the State of California in a local court to take a school section (section sixteen) by eminent domain for waterworks and related projects. That land had been granted to the State for schools long before the area was included in a federal Mono Forest Reserve. State officials had offered the land as a base for selecting other public lands in lieu, and some selections were pending in the General Land Office.
Reasoning
The core question was whether a State may give up (waive) its right to a surveyed school section that later becomes part of a federal forest reservation and instead choose other public lands under a federal law (Section 2275). The Court read the statute’s proviso to allow the State to make such a waiver when the reservation was created after the land was surveyed and the State’s title had vested. The opinion relied on the Interior Department’s long-standing interpretation of the law, the practical reliance on that interpretation, and the statute’s purpose to preserve forest reservations while letting States obtain replacement lands.
Real world impact
Because the Court found the federal statute permits these exchanges, the California decision that had treated the section as simply state land subject to condemnation was held to be wrong on the federal question. The case was sent back to the state court to proceed consistent with the Court’s reading of the federal law. The ruling affects how surveyed school lands inside later federal reservations are treated and how States and private parties may rely on federal land-selection practices.
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