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City of Santa Maria v. Adam

ELR Citation: 42 ELR 20241
Nos. H032750, (Cal. Ct. App. 6th Dist., 11/21/2012)

A California appellate court affirmed in part and reversed in part a lower court decision approving an agreement between landowners, the Santa Maria Valley Water Conservation District, and local cities and water companies in a water rights dispute over the groundwater contained in the Santa Maria Valley Groundwater Basin. The stipulation contains a plan, referred to as a physical solution, that resolves conflicting water rights claims and allocates the various components of the groundwater among the stipulating parties. A group of farmers who did not join the stipulation filed suit challenging certain portions of the stipulation and sought to quiet title to their prior rights to water in the basin. The trial court properly exercised its equitable powers to approve the physical solution proposed by the stipulating parties. The present existence of a water shortage is not a prerequisite to imposition of a physical solution. The evidence is also sufficient to support the trial court's finding that a city and local water company have perfected prescriptive rights, giving them a prior right to a specified volume of groundwater in the event of a future water shortage. Although recent water surpluses make it unnecessary to assert that priority, the prescriptive rights have not been extinguished by nonuse. But the court reversed the trial court's rejection of the farmers' quiet title claims. The farmers are entitled to a judgment declaring their overlying rights to be prior to all appropriative rights in the native groundwater, less the volume to which the water producers are entitled due to their prescriptive rights. And although the court affirmed the trial court's approval of the stipulating parties' allocation of return flows and salvaged water, the stipulation must be clarified to insure that the water producers' priority right to the salvaged water does not exceed the amount of water actually saved.