Estate of Boyd v. United States
32,119
N.M. Ct. App.Oct 15, 2014Background
- Boyd intervened in the Lower Rio Grande water rights adjudication seeking rights stemming from the Rio Grande Dam & Irrigation Company's historic project.
- District court dismissed Boyd’s claims for failure to state a cognizable water right and due to res judicata.
- Historical groundwork includes the 1891 Act granting rights of way for irrigation and the Company’s long dispute with the United States over completion and forfeiture of rights.
- Earlier forfeiture rulings were affirmed by the Territory NM Supreme Court and by the U.S. Supreme Court; the Company’s project was not completed.
- Boyd argued a continuing, non-forfeited right under the Mendenhall doctrine, but the court distinguished it, finding forfeiture due to non-response to the supplemental complaint.
- Court also addressed Boyd’s fraud/conspiracy theories, concluding they are unsupported and that federal remedies apply to federal actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boyd stated a cognizable water right claim | Boyd asserts ongoing rights from the original project. | Defendants contend Boyd cannot claim existing water rights absent actual diversion and beneficial use. | No; Boyd failed to state an existing water right. |
| Whether res judicata bars Boyd’s claims | Boyd contends privity issues prevent preclusion. | District court properly found privity via successor in interest to the Company. | Yes; all four elements of res judicata are met, precluding Boyd’s claims. |
| Whether Boyd's fraud/conspiracy claims invalidate the forfeiture decree | United States and Company attorneys conspired to void rights. | Record shows potential attorney strategy but not a conspiracy; FA Act applies. | No; claims are unfounded and federal remedies apply; no state-law fraud/conspiracy relief. |
Key Cases Cited
- Rio Grande Dam & Irrigation Co. v. United States, 215 U.S. 266 (U.S. Supreme Court (1909)) (forfeiture and rights-range issues in federal adjudication; final on merits)
- Rio Grande Dam & Irrigation Co., 1906-NMSC-013 (NM Supreme Court (1906)) (forfeiture affirmed; prior adjudications on merits)
- Rio Grande Dam & Irrigation Co., 1900-NMSC-042 (NM Supreme Court (1900)) (dismissal and navigability considerations; remand for hearings)
- State ex rel. Reynolds v. Mendenhall, 1961-NMSC-083 (NM Supreme Court (1961)) (Mendenhall doctrine; non-use forfeiture distinctions)
- State ex rel. Reynolds v. Miranda, 1972-NMSC-003 (NM Supreme Court (1972)) (essential elements of appropriation and beneficial use)