City of Santa Maria v. Adam
248 Cal. App. 4th 504
| Cal. Ct. App. | 2016Background
- This is the second appeal in long-running litigation over groundwater rights in the Santa Maria Valley Groundwater Basin between landowners (LOG) asserting overlying rights and public water producers asserting appropriative/prescriptive rights.
- In the first appeal (City of Santa Maria v. Adam), the court instructed the trial court to quiet title to appellants’ overlying rights as prior to appropriators except to the extent respondents had prescriptive rights, and to reconsider prevailing-party/costs if necessary.
- On remand the trial court amended its judgment: it declared LOG’s overlying rights prior and paramount to appropriative rights but subject to the prescriptive rights proved for City of Santa Maria (5,100 acre-feet/year) and Golden State Water Company (1,900 afy). Those prescriptive rights were fixed against the aquifer as a whole.
- The trial court declined to quantify the specific proportion of respondents’ prescriptive rights that could be attributed to individual LOG parcels, reasoning quantification is unnecessary absent a shortage/overdraft.
- The trial court also declined to revisit its earlier prevailing-party determination (which had favored respondents), concluding respondents obtained primary relief in the overall litigation.
Issues
| Issue | Plaintiff's Argument (LOG) | Defendant's Argument (Respondents) | Held |
|---|---|---|---|
| Whether the trial court must quantify the proportionate prescriptive loss attributable to each LOG parcel to quiet title | Quantification is required so title is not illusory and owners can protect/enforce rights and market property | Not necessary until an actual shortage; prescriptive amounts are already quantified against basin as a whole | No error: quantification of parcel-by-parcel prescriptive loss is not required to quiet title while basin has surplus; judgment properly declares priorities |
| Whether wording in the amended judgment (use of "prior") creates confusion or gives prescriptive rights "super priority" | The term could be mistaken to mean prescriptive rights have superior priority over overlying rights and thus needs modification | The word "prior" refers to previously established prescriptive rights; no plausible prejudice shown | No modification required; wording reasonably clear and LOG failed to demonstrate prejudicial error |
| Whether the trial court erred by not changing the prevailing-party determination on remand | Reversal on appeal means LOG obtained primary relief (quiet title) and thus should be prevailing party entitled to costs | Respondents obtained primary relief in the overall litigation (prescriptive rights affirmed, physical solution and return-flow allocations affirmed); court has discretion | No abuse of discretion: trial court correctly left prevailing-party determination for respondents because they obtained the primary relief in the litigation |
| Whether the amended judgment is illusory and will force relitigation of prescription issues later | LOG: absence of parcel-specific allocations leaves cloud on title and forces future litigation | Respondents: prescriptive volumes are fixed; parcel allocation only needed on future overdraft when correlative shares are determined | Judgment is not illusory; it prevents further erosion of overlying rights and parcel-level allocation can await a future overdraft event |
Key Cases Cited
- City of Barstow v. Mojave Water Agency, 23 Cal.4th 1224 (overlying rights measured by present and prospective reasonable beneficial use)
- City of Los Angeles v. City of San Fernando, 14 Cal.3d 199 (prescriptive groundwater rights fixed to quantity pumped during prescriptive period)
- City of L.A. v. City of Glendale, 23 Cal.2d 68 (quiet-title actions determine priority of rights, not precise future quantities)
- Cuyamaca Water Co. v. Superior Court, 193 Cal. 584 (quiet-title relief focuses on priority, not exact quantity allocations)
- Hi-Desert County Water Dist. v. Blue Skies Country Club, Inc., 23 Cal.App.4th 1723 (new prescriptive rights may be acquired during future overdraft; self-help can interrupt prescriptive period)
- City of Pasadena v. City of Alhambra, 33 Cal.2d 908 (in times of surplus, injunctions to restrain appropriations are generally unavailable)
- Villa De Las Palmas Homeowners Assn. v. Terifaj, 33 Cal.4th 73 (standard of review and discretion on prevailing-party determinations)