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 Pueblos of Laguna and Acoma were involved in a water rights adjudication initiated by the New Mexico State Engineer concerning the Rio San Jose stream system in Cibola County, New Mexico. The dispute arose from prior settlements with the United States government through the Indian Claims Commission (ICC) over land and water rights, including claims for lost water rights due to the enlargement of the Bluewater Dam in 1927. The Pueblos argued that their water rights were not extinguished by the ICC proceedings, while the State Engineer contended otherwise (paras 1-7).
Procedural History
- Indian Claims Commission, 1967: The ICC determined that the Pueblos had lost title to aboriginal lands and appurtenant water rights but found no proof of water loss on retained lands due to the Bluewater Dam (paras 5, 19).
- District Court of Cibola County, (N/A): The district court granted partial summary judgment against the Pueblos, holding that their claims were precluded by the ICC proceedings and settlements. It also ruled that the Pueblos had no "Winters doctrine water rights" appurtenant to their grant lands (paras 1, 7).
Parties' Submissions
- Appellants (Pueblos of Laguna and Acoma): Argued that the ICC proceedings did not extinguish their water rights on retained lands and that the settlements did not compensate for such rights. They also contended that the district court erred in ruling that the Winters doctrine did not apply to their grant lands (paras 8, 28-30).
- Respondent (State of New Mexico): Asserted that the ICC proceedings and settlements precluded the Pueblos from relitigating water rights claims. The State also argued that the Winters doctrine did not apply to the Pueblos' grant lands, as these lands were not federally reserved (paras 8-9, 28).
Legal Issues
- Did the ICC proceedings and settlements preclude the Pueblos from asserting water rights appurtenant to retained lands?
- Does the Winters doctrine apply to the Pueblos' grant lands?
Disposition
- The Court of Appeals reversed the district court's ruling that the ICC proceedings and settlements precluded the Pueblos' claims to water rights on retained lands (para 32).
- The Court of Appeals affirmed the district court's ruling that the Winters doctrine does not apply to the Pueblos' grant lands (para 32).
Reasons
Per Bosson J. (Apodaca CJ. and Minzner J. concurring):
Preclusion by ICC Proceedings and Settlements: The court held that the ICC's limited jurisdiction, which was restricted to monetary compensation, did not allow the Pueblos to assert ownership of water rights against non-Indian parties or the State of New Mexico. The ICC findings did not conclusively determine the issue of water rights on retained lands, and the settlements were ambiguous regarding compensation for such rights. Therefore, the Pueblos were not precluded from asserting these claims (paras 11-24).
Winters Doctrine: The court affirmed that the Winters doctrine does not apply to the Pueblos' grant lands because these lands were not federally reserved but rather recognized as already owned by the Pueblos under Spanish and Mexican grants. The court relied on the reasoning in State v. Aamodt, which distinguished between recognition of existing rights and reservation of new rights (paras 28-31).