Quigley v. Beck, 405 P.3d 627

James and Linda Quigley and Richard Beck own adjoining parcels that were formerly one property (Finn Ranch) to which the 1909 Geary v. Raymond decree awarded four Nevada Creek irrigation rights to John W. Blair.
Finn Ranch was split and sold in 1912; subsequent deeds did not expressly reserve or allocate the decreed water rights between the resulting parcels.
Both Quigley’s and Beck’s predecessors timely claimed the same four decreed Nevada Creek rights, and each claimed the full flow amounts, triggering DNRC “decree exceeded” remarks.
The consolidated adjudication was assigned to a Water Master who, after trial and site inspection, found each party was successor to portions of the four rights and apportioned the decreed flows using the Spaeth proportional-acreage formula (Beck 70%, Quigley 30%).
The Water Court reviewed objections, largely adopted the Water Master’s report, and Quigley appealed to the Montana Supreme Court challenging (1) interpretation of the 1909 Geary decree and (2) application of the clear-error standard to the Water Master’s factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Geary decree appurtenanced the four Nevada Creek rights only to the specific parcels Blair described in his pleadings	Quigley: decree must be read to incorporate Blair’s answer/amended answer so rights attach only to the specific parcels described therein	Beck: decree did not attach rights to particular parcels within Finn Ranch; rights are appurtenant to the irrigated lands of Finn Ranch generally	Court held the decree did not incorporate Blair’s pleadings to limit places of use; rights were appurtenant to the irrigated lands of Finn Ranch and thus could be apportioned to Beck’s parcels
Whether the Water Master misapplied/apprehended evidence and lacked substantial evidence to find rights appurtenant to Beck’s land	Quigley: evidence shows some rights were used exclusively or predominantly on what is now Quigley’s land; Master misweighed evidence and Spaeth allocation shortchanges Quigley	Beck: decree plus witness testimony and historic use evidence support appurtenance to both parcels; Spaeth formula proper where place-of-use proof is inconclusive	Court held Master’s factual findings were supported by substantial evidence, the Master did not misapprehend evidence, and application of Spaeth was appropriate; no clear error

Spaeth v. Emmett, 142 Mont. 231, 383 P.2d 812 (1963) (establishes proportional division of appurtenant water rights by irrigated acres when tract divided)
Castillo v. Kunnemann, 197 Mont. 190, 642 P.2d 1019 (1982) (decree plus testimony showing traditional irrigation from the ditch can establish appurtenance to a subdivided parcel)
MacLay v. Missoula Irrigation Dist., 90 Mont. 344, 3 P.2d 286 (1921) (a water right acquired and used for a tract is an appurtenance that passes with the land unless reserved)
Skelton Ranch, Inc. v. Pondera Cnty. Canal & Reservoir Co., 375 Mont. 327, 328 P.3d 644 (2014) (Water Court reviews Water Master’s findings for clear error and conclusions of law for correctness)
Granite County Bd. of Comm’rs v. McDonald, 385 Mont. 262, 383 P.3d 740 (2016) (interpretation of prior decree is a question of law reviewed for correctness)