Lux v. Haggin facts for kids
Quick facts for kids Lux v. Haggin |
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Supreme Court of California
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| Decided April 26, 1886 | |
| Full case name | Charles Lux et al., Appellants, v. James B. Haggin et al. The Kern River Land and Canal Company, Respondent |
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| Holding | |
| Riparian water rights are superior to appropriative water rights. Appropriation of water for public use is permitted with just compensation. | |
| Court membership | |
| Chief Justice | Robert F. Morrison |
| Associate Justices | Elisha W. McKinstry, Samuel B. McKee, John R. Sharpstein, James D. Thornton, Erskine M. Ross, Milton H. Myrick |
| Case opinions | |
| Majority | McKinstry |
| Concurrence | McKee, Sharpstein, Thornton |
| Dissent | Ross , joined by Morrison |
| Dissent | Myrick |
Lux v. Haggin was a very important court case in California in 1886. It helped decide who had the right to use water. This case was about two different ways people claimed water: riparian rights and appropriative water rights. The California Supreme Court decided that riparian rights were more important than appropriative rights.
Contents
Understanding Water Rights in California
California adopted two main systems for water rights. These systems often caused problems because they had different rules.
What are Riparian Rights?
In 1850, California started using a system called common law. This system said that if you owned land next to a river or stream, you had the right to use the water. This is called a riparian right. You could use the water for your home and for small farming. But you could not stop other landowners along the same river from using the water too.
What are Appropriative Rights?
Later, in 1855, California added another water rights system. This one was called prior appropriation. It was based on a "first come, first served" idea. This system was helpful for miners and farmers whose land was not next to a river. The first person to claim and use water from a source had the strongest right to it. Later users could only take water if it did not harm the first user's supply. This system did not limit how much water someone could claim.
Why the Conflict?
These two systems clashed. Riparian rights said that owning land next to water gave you an automatic right to use it. Appropriative rights said that the first person to use the water had the best claim. The Lux v. Haggin case was important because it helped California decide which water right system would be stronger.
The People Involved
This court case involved two main groups of people who needed water for their businesses.
Henry Miller and Charles Lux
Henry Miller and Charles Lux were business partners. They started as butchers in San Francisco. Later, they bought a lot of land in Kern County. Their land was next to a swampy area called Buena Vista Slough, which was fed by the Kern River. Because their land was next to the slough, Miller and Lux believed they had riparian rights to the water. They built many canals to bring water from the slough to their land for their cattle. But in 1877, the slough dried up completely. This happened because people upstream were taking too much water. About 10,000 of Miller and Lux's cattle died that year.
James Ben Ali Haggin
James Ben Ali Haggin was a lawyer and businessman. He owned the Kern County Land and Canal Company. His company was located along the Kern River, upstream from Miller and Lux's land. Haggin used appropriative water rights to take water from the Kern River. He used this water to irrigate his large farms in Kern County. By 1877, Haggin's company had taken so much water that the Kern River no longer flowed to Buena Vista Slough.
The Court Battles
The dispute between Miller and Lux and Haggin led to several court cases.
First Case: Lux v. Haggin (1881)
Miller and Lux first sued Haggin in 1879. A big question in this case was whether Buena Vista Slough was truly a "watercourse." If it was, then Miller and Lux would have riparian rights. Miller and Lux argued that the slough was part of the Kern River system. Haggin argued that the slough was just swampland, not a real river channel. In 1881, the judge decided that the slough was not a clear watercourse. This meant Miller and Lux were not considered riparian landowners. The judge also said that taking water for irrigation was a "natural necessity" in California.
Appeal: Lux v. Haggin (1884)
Miller and Lux did not give up. In 1884, they appealed the 1881 decision to the California Supreme Court. They argued that Haggin's actions had moved the Kern River far from its natural path. They said Haggin had turned their watery land into a desert. Miller and Lux claimed that Haggin had violated their property rights. The Supreme Court agreed with Miller and Lux. They overturned the earlier ruling by a vote of four to three.
The Big Question for the Court
The main question in Lux v. Haggin was how California would handle water rights. Would the court stick with the old English common law (riparian rights)? Would it make appropriative rights the most important? Or would it create a brand new system?
In 1886, the California Supreme Court heard the case again. They specifically asked: "Can a private company take water from a river and stop landowners along that river from using it, without paying them fairly?"
The Court's Decision
The court decided to uphold riparian rights as the most important. The vote was four to three. Justice McKinstry wrote the main opinion. He said that landowners next to a river have a clear right to use its water.
However, Justice McKinstry also said that water could be used for public purposes. This meant that irrigation companies could take water, but they had to pay a fair price to the riparian landowners whose water use was affected.
Why This Case Was Important
Lux v. Haggin was a landmark case for water rights in California. At this time, California's population was growing fast. More and more water was needed for farms and cities. The court had a chance to decide which water system would be best for the state's future.
In the end, the court recognized both riparian and appropriative water rights. But it made it clear that appropriative rights were secondary to riparian rights. This decision caused some confusion because it meant California had two different ways of sharing water that did not always work well together.
The court also changed the meaning of "reasonable" water use for riparian owners. Before, it mostly meant water for homes and small farms. After this case, riparian landowners could use water for bigger commercial and agricultural purposes. As long as their use did not harm other riparian landowners. This meant riparian landowners could now use much more water than before.
