In the 1910 case of Rickey Land and Cattle Company v. Miller and Lux, the U.S Supreme Court dealt with a dispute over water rights in California. The Rickey Land and Cattle Company claimed that they had acquired prescriptive rights to use water from a river running through land owned by Miller & Lux. However, Miller & Lux argued that their predecessors had continuously used this water for irrigation since before Rickey's claim began, thus establishing their own prescriptive right to its use. The court ruled in favor of Miller & Lux, holding that continuous usage established an easement or servitude on the property which could not be extinguished simply because someone else later made beneficial use of it without protest from the owner. This decision reinforced prior appropriation doctrine - "first in time is first in right" - as governing principle for allocating water resources among users in western states where scarcity makes such allocation necessary.

In the dissenting opinion for Rickey Land and Cattle Company v. Miller and Lux, it was argued that the majority's decision to uphold a lower court ruling in favor of Miller and Lux was incorrect. The dissenting justices believed that Rickey Land had a legitimate claim to water rights from White River, which ran through both parties' properties. They contended that by diverting water upstream for their own use, Miller and Lux were infringing on Rickey Land's right to reasonable use of the river as established under California law at the time. Furthermore, they disagreed with the majority's interpretation of "reasonable use," arguing instead that each riparian owner should have an equal right to beneficially utilize shared resources without causing undue harm or waste - a principle they felt was not upheld in this case due to what they perceived as excessive diversion by Miller & Lux.