Agua Caliente Band of Cahuilla Indians v. Coachella Valley Water District, No. 15-55896 (9th Cir. 2017)
Annotate this CaseIn this interlocutory appeal, the water agencies challenged the district court's grant of partial summary judgment for the Tribe and the United States. The judgment declared that the United States impliedly reserved appurtenant water sources, including groundwater, when it created the Tribe's reservation in California's arid Coachella Valley. The court concluded that in the Winters v. United States doctrine, federal reserved water rights are directly applicable to Indian reservations and other federal enclaves, encompassing water rights in navigable and nonnavigable streams; the Winters doctrine does not distinguish between surface water and groundwater; rather, its limits derive only from the government's intent in withdrawing land for a public purpose and the location of the water in relation to the reservation created; because the United States intended to reserve water when it established a home for the Tribe, the court held that the district court did not err in determining that the government reserved appurtenant water sources—including groundwater—when it created the Tribe's reservation in the Coachella Valley; and the creation of the Agua Caliente Reservation carried with it an implied right to use water from the Coachella Valley aquifer. The court held that state water rights were preempted by federal reserved rights; held that the fact that the Tribe did not historically access groundwater does not destroy its right to groundwater now; and held that state water entitlements do not affect the court's analysis with respect to the creation of the Tribe's federally reserved water right. Accordingly, the court affirmed the judgment.
Court Description: Water Rights / Tribal Rights. The panel affirmed the district court’s partial summary judgment in favor of the Agua Caliente Band of Cahuilla Indians and the United States, which declared that the United States impliedly reserved appurtenant water sources, including groundwater, when it created the Tribe’s reservation in California’s arid Coachella Valley. The Tribe filed this action for declaratory and injunctive relief against water agencies, and the parties stipulated to divide the litigation into three phases. Phase I, at issue in this interlocutory appeal, addressed whether the Tribe has a reserved right to groundwater. Under the doctrine in Winters v. United States, 207 U.S. 564 (1908), federal reserved water rights are directly applicable to Indian reservations. The panel held that the Winters doctrine does not distinguish between surface water and groundwater. The panel held that the United States, in establishing the Agua Caliente reservation, impliedly reserved water. The panel further held that because the United States intended to reserve water when it established a home for the Agua Caliente Band of Cahuilla Indians, the district court did not err in determining that the government reserved appurtenant water sources – including groundwater – when it created the
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