In the 1896 case of Fallbrook Irrigation District v. Bradley, the U.S. Supreme Court ruled on a dispute involving water rights and eminent domain in California. The Fallbrook Irrigation District had attempted to use its power of eminent domain to take private property for public use, specifically for irrigation purposes. However, the landowners argued that this was not a legitimate public purpose and therefore violated their Fifth Amendment rights against taking without just compensation. The court sided with the irrigation district, ruling that providing water for agriculture could be considered a valid public use under certain circumstances because it served an important economic function within arid regions like Southern California where farming was crucial but difficult due to lack of rainfall. This decision expanded interpretations of "public use" in relation to eminent domain law by recognizing indirect benefits such as economic development or improvement as potential justifications for government takings.

In the dissenting opinion for Fallbrook Irrigation District v. Bradley, Justice Brewer argued that the majority's decision to uphold California's irrigation law violated property rights protected by the Fourteenth Amendment. He contended that while public use could justify eminent domain, it was not clear how private landowners benefited from having their water redirected to other people’s lands. The justice also questioned whether a jury of freeholders (landowners) would provide an impartial assessment of just compensation for seized property since they might stand to benefit from lower assessments themselves. Furthermore, he criticized the majority for deferring too much to state legislatures in determining what constitutes public use and fair compensation under eminent domain laws. In his view, this deference threatened individual liberties by allowing states too much power over private properties without sufficient checks or balances.