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State Of California v. Deseret Water, Oil & Irrigation Company

• 1916 • 243 U.S. 415 • White Court
In the case of State of California v. Deseret Water, Oil & Irrigation Company in 1916, the Supreme Court was tasked with resolving a dispute over water rights between the state and a private company. The State of California claimed that it had exclusive rights to all unappropriated waters within its borders under an act passed by Congress in 1866. Meanwhile, Deseret Water argued that they had acquired valid water rights through their extensive use and development of certain streams for...Open Case
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Chief White Court
Term: 1916
Docket: 269
243 U.S. 415
37 S. Ct. 394
61 L. Ed. 821
1917 U.S. LEXIS 2035
Argued: Jan 29, 1917

State Of California v. Deseret Water, Oil & Irrigation Company

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Opinion Summary
AI Abstract

In the case of State of California v. Deseret Water, Oil & Irrigation Company in 1916, the Supreme Court was tasked with resolving a dispute over water rights between the state and a private company. The State of California claimed that it had exclusive rights to all unappropriated waters within its borders under an act passed by Congress in 1866. Meanwhile, Deseret Water argued that they had acquired valid water rights through their extensive use and development of certain streams for irrigation purposes prior to this legislation being enacted. The Supreme Court ruled in favor of Deseret Water, stating that while states do have broad powers to control and distribute their own natural resources including water, these powers are not absolute or retroactive. Therefore, any usage or appropriation made before such laws come into effect must be respected unless explicitly revoked by subsequent legislation. This decision underscored the importance of respecting established property rights even when dealing with shared resources like waterways. It also highlighted how federal law can sometimes limit state authority over local issues - particularly those involving interstate commerce or other matters which fall under Congressional jurisdiction.

Dissent Summary
AI Abstract

The dissenting opinion in the case of State of California v. Deseret Water, Oil & Irrigation Company argued that the majority's decision to uphold California's right to tax property owned by a Utah corporation was incorrect. The dissenting justices believed that this ruling violated the Due Process Clause of the Fourteenth Amendment, which protects against state infringement on personal jurisdiction and property rights without due process of law. They contended that because Deseret Water, Oil & Irrigation Company was incorporated in Utah and its primary operations were based there, it should not be subject to taxation by another state where it merely held some properties as investments but did not conduct any business activities. This interpretation would prevent states from overreaching their taxing authority at the expense of out-of-state corporations' constitutional rights.

Opinion written by Justice WRDay
Decided: Mar 26, 1917
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