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Phillips v. Mound City Land and Water Association was a United States Supreme Court case that dealt with the issue of water rights. The case involved a dispute between the Mound City Land and Water Association and the Phillips family over the use of a stream of water that ran through the Phillips’ land. The Association had been granted a right to use the water for irrigation purposes, but the Phillips family argued that they had a prior right to the water and that the Association’s use of the water was infringing on their rights. The Supreme Court ultimately sided with the Phillips family, ruling that the Association’s use of the water was in violation of the Phillips’ prior right to the water. The Court held that the Association’s right to use the water was limited to the amount of water necessary for irrigation purposes, and that any additional use of the water was in violation of the Phillips’ prior right. The Court also held that the Phillips family was entitled to compensation for any damages caused by the Association’s use of the water.
In Phillips v. Mound City Land and Water Association, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a non-resident against a corporation organized under the laws of another state. The majority opinion held that it did not have such jurisdiction because there was no showing that the defendant had any property or other presence in the forum state sufficient to give rise to personal jurisdiction. Justice Field dissented from this decision, arguing that due process requires only minimal contacts with the forum state for personal jurisdiction and those contacts were present here given that some of its members resided in Missouri and it conducted business within its borders. He argued further that since corporations are creatures of statute they should be subject to suit wherever their activities take them regardless of where they are incorporated or headquartered as long as minimum contacts exist between them and the forum state.