Redrock Valley Ranch v. Washoe County

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Justia Opinion Summary

Redrock Valley Ranch (RVR) proposed to export water from one hydrographic basin to another in northern Nevada. Both basins lie in Washoe County. The state engineer approved the transfer applications. The county, however, declined to grant RVR a special use permit for the pipelines, pump houses, and other infrastructure needed to make the water exportation plan a reality after determining that the issuance of the special use permit could potentially be detrimental to the public, adjacent properties, or surrounding area. The district court upheld the denial of the special use permit, concluding that substantial evidence supported the county's decision and that the denial did not amount to an abuse of discretion. RVR appealed, arguing that the county did not have authority to deny the special use permit application. The Supreme Court affirmed, holding that the state engineer's ruling neither preempted nor precluded the county from denying RVR's application for a special use permit for the reasons it did and that substantial relevant evidence supported the county's denial of the permit.