WATER: Rights to Teton River water dating back to 1874 properly determined except that irrigation effort begun in 1880 and completed in 1887 constituted single priority date in 1880… Ritter affirmed, reversed. [Read more…]
Water, presumption of municipal abandonment
WATER: §85-2-227(4) presumption of municipal nonabandonment procedural, not impermissibly applied retroactively… properly applied as to 7.35 cfs of creek, objector failed to rebut… City improperly found to have abandoned .6 cfs in light of “growing communities” doctrine… challenge to place-of-use restrictions fails for lack of notice AG… Tucker affirmed, reversed. [Read more…]
Water, BLM reservoirs, use by grazers
WATER: BLM entitled to proceed under Montana law to appropriate water in its reservoirs for use by grazing permittees and others… Ritter affirmed.
BLM filed 6 claims related to 5 reservoirs based on Montana law and a natural pothole (Pothole Lake) based on a federal reservation of lands. The sources are wholly or partly on federal land, and BLM claims the right to use each for stockwatering by its grazing permittees and wildlife. The Water Master recommended summary judgment for BLM on each claim. Stockowners objected, stating the issue as whether BLM “under applicable state and federal laws, actually made appropriations for beneficial use.” They contend that BLM did not perfect any rights and sought an order transferring all the claimed BLM rights to the current grazing permittee and terminating all wildlife claims. Judge Ritter upheld the Master’s recommendation in most respects. Objectors appeal.
Ritter did not err in concluding that BLM holds stockwater rights under Montana law in reservoirs on federal land, for the use of grazing permittees. Under the law established in Bailey (Mont. 1912), relied on by both parties, there is no “public service corporation rule,” but only recognition of a public policy of the State to allow and even encourage individuals and entities to appropriate water and make it available for use by others. We reject Objectors’ argument that BLM cannot appropriate water because it does not separately charge grazers for use of the reservoir water. As long as the water is made available for sale, rental, or distribution or disposal to others, id., it is a valid appropriation under Bailey. Montana law “clearly shows a steadfast commitment to recognizing the ability to appropriate water for its ultimate use by a third party.” Curry (Mont. 2016). Contrary to the Dissent’s argument that BLM has never put water to a beneficial use, Art. IX §3(2) states: “The use of all water that is now or may hereafter be appropriated for sale, rent, distribution, or other beneficial use … and the sites for reservoirs necessary for collecting and storing water shall be held to be a public use.” Nor can Objectors’ argument that BLM’s claims are invalid because it “simply facilitated use of water already appropriated” by their ancestral free grazers be supported under Montana law. It has long been the common law and then statutory law in Montana that multiple appropriators can claim rights from the same source and that the first in time has the best right. It is well known that there have been so many appropriators on some sources that the waters have become “over appropriated.” Trout Unlimited (Mont. 2006) While that creates its own issues, it does not mean that the one that made the first use acquired the right to exclude any others from claiming water from the same source.
Ritter correctly concluded that Pothole Lake was reserved by an act of Congress in 1926 and that nothing raised by Objectors supports any change in that status.
McGrath, Cotter, Wheat, Baker, Shea, Rice.
McKinnon dissented: The Majority’s conclusions that Stockowners’ claims are separate from BLM’s claims ignore that they share the same beneficial use: BLM’s claims are premised on actual beneficial use of water consumed by Stockowners’ cattle. To conclude that BLM has perfected its claim, which may only be characterized as overlapping Stockowners’ claim, the Majority again revisits Bailey and further erodes the long-established principle in western water law that application of water to beneficial use is essential to a completed appropriation. By concluding that BLM has a right in the samewater which has been placed to an actual beneficial use for over a century by Stockowners, the Majority distorts Bailey, fails to address well-reasoned Montana and federal law, and upends the touchstone of the prior appropriation doctrine.
Claimant: BLM; Objectors: Barthelmess Ranch et al, DA 15-533, argued 9/23/16, decided 12/28/16.
John Cruden, Elizabeth Peterson, John Smeltzer, James Dubois, and Anna Stimmel (USDOJ); John Bloomquist & Rachel Meredith (Bloomuist Law Firm), Helena, for Objectors.
Water, dissatisfied user complaint
WATER: Dissatisfied user complaint properly denied… Olson affirmed. [Read more…]
Water, standard of review, water volume
WATER: Incorrect standard of review of Water Master Ritter’s findings by Water Court nonetheless produced proper water volume result… McElyea affirmed. [Read more…]
Water, Pondera rights rulings
WATER: Pondera rights rulings affirmed, reversed. [Read more…]
Water, Eureka Reservoir, 1890 canal rights
WATER: Off-stream storage in Eureka Reservoir not included in 1890 canal rights… Ritter reversed. [Read more…]
Public access, $375,000 for bridge restoration
PUBLIC ACCESS EASEMENT: Advisory jury’s verdict of $375,000 properly adopted as supplemental declaratory relief for “restoration” of public access bridge that had been moved from canal crossing… fees/ costs properly awarded PLWA, but improperly ordered taken out of $375,000 restoration fund, remanded for separate award… Olson affirmed, reversed. [Read more…]
Water, no private right to deliver
WATER: No private right to deliver water through ditch… rights that can be diverted properly listed… McElyea affirmed, reversed. [Read more…]
$410,000 verdict, bridge easement interference
VERDICT: $410,000, tortious interference with public easement over bridge, public nuisance… trial following Supreme Court ruling that public prescriptive easement not limited to bridge destroyed by wildfire, includes replacement bridge in place at time of prior MSC decision which became law of case. [Read more…]