This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Village of Wagon Mound, the Mora Trust, and the Berliers disputed ownership, use, and access to water from the Santa Clara Spring, the sole water source for the Village and surrounding lands for over 65 years. The Village relied on a 1935 contract and 1936 indenture with the original landowner, Calley, to claim perpetual rights to the Spring's water. The Mora Trust, which acquired the land in 1992, challenged the validity of these agreements and the Village's water rights (paras 1-16).
Procedural History
- District Court, September 11, 2000: Granted summary judgment in favor of the Village, declaring the 1935 contract and 1936 indenture valid and enforceable, and recognizing the Village's perpetual right to use the Spring's water. The court relied on the doctrine of laches to bar the Mora Trust's claims (paras 23-24).
- District Court, October 26, 2000: Granted summary judgment in favor of the Berliers, declaring the division of water rights under License No. 2682 and rejecting the Mora Trust's claims of pre-1907 water rights, slander of title, and abandonment of water rights by the Berliers (paras 53-54).
Parties' Submissions
- Appellant (Mora Trust): Argued that the Village lacked statutory or vested pre-1907 water rights, the doctrine of laches was improperly applied, and the pipeline easement was void. Additionally, the Trust claimed pre-1907 water rights, disputed the division of water rights under License No. 2682, and alleged slander of title by the Berliers (paras 2, 24, 54-56).
- Appellee (Village of Wagon Mound): Asserted that the 1935 contract and 1936 indenture created enforceable contractual rights to use the Spring's water and that the Trust's claims were barred by laches. The Village did not claim statutory or pre-1907 water rights (paras 21-24, 30-36).
- Appellee (Berliers): Contended that the water rights were properly divided under License No. 2682 and that the Trust failed to prove pre-1907 rights or abandonment of water rights. They denied slandering the Trust's title (paras 54-56).
Legal Issues
- Did the Village of Wagon Mound have enforceable water rights under the 1935 contract and 1936 indenture?
- Was the doctrine of laches properly applied to bar the Mora Trust's claims?
- Was the pipeline easement valid and enforceable?
- Did the Mora Trust have pre-1907 water rights in the Spring?
- Were the water rights under License No. 2682 properly divided between the Mora Trust and the Berliers?
- Did the Berliers slander the Mora Trust's title to water rights?
- Did the Mora Trust own 100% of the benefits flowing from the contract and indenture with the Village?
Disposition
- The Court of Appeals affirmed the summary judgment in favor of the Village, upholding the enforceability of the 1935 contract and 1936 indenture but clarified that the Village did not have a statutory or vested water right (paras 77-78).
- The Court of Appeals affirmed the summary judgment in favor of the Berliers on most issues but reversed and remanded on the ownership of the distribution system and the benefits flowing from the contract and indenture (paras 78-79).
Reasons
Per Bustamante J. (Castillo and Robinson JJ. concurring):
Enforceability of the Contract and Indenture: The Court held that the 1935 contract and 1936 indenture created enforceable contractual rights for the Village to use the Spring's water. The agreements did not transfer a statutory or vested water right but allowed the Village to use water as a matter of contract. The Trust and the Berliers were bound by these agreements, as they acquired the land subject to them (paras 30-36).
Application of Laches: The Court upheld the application of laches, finding that the Trust's 61-year delay in challenging the agreements was unreasonable and prejudicial to the Village, which had relied on the Spring as its sole water source (paras 35-36).
Pipeline Easement: The Court recognized the validity of the "floating" easement, as the pipeline's location had been established through construction and continuous use for over 60 years. The easement was enforceable despite the lack of a specific description in the original documents (paras 44-52).
Pre-1907 Water Rights: The Court found that the Trust failed to provide evidence of continuous beneficial use of pre-1907 water rights for the additional 104.45 acres it claimed. The Trust could not identify the location of the land or prove irrigation prior to 1907 (paras 61-64).
Division of Water Rights: The Court affirmed the district court's calculation of water rights under License No. 2682, finding that the rights were proportionally divided based on the acreage conveyed to the Trust and the Berliers. The Trust's claim of superior rights was unsupported by the record (paras 65-70).
Slander of Title: The Court rejected the Trust's claim of slander of title, finding that the Berliers' filing of a Change of Ownership form accurately reflected their proportional ownership of water rights under License No. 2682 (paras 73-74).
Ownership of Benefits from the Contract and Indenture: The Court found ambiguity in the Exchange Agreement regarding whether the Trust was entitled to all benefits flowing from the contract and indenture with the Village. This issue was remanded for further proceedings (paras 75-76).