Dept. of Water Resources Cases

CourtCalifornia Court of Appeal
DecidedMarch 26, 2026
DocketC103207
StatusPublished

This text of Dept. of Water Resources Cases (Dept. of Water Resources Cases) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dept. of Water Resources Cases, (Cal. Ct. App. 2026).

Opinion

Filed 3/26/26 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (San Joaquin) ----

DEPARTMENT OF WATER RESOURCES CASES C103207

(JCCP 4594)

(San Joaquin Super. Ct. Nos. STK-CV-UED-2023-0008476, STK-CV-UED-2024-0006729, STK-CV-UED-2024-0006894, STK-CV-UED-2024-0006737, STK-CV-UED-2024-0006722, STK-CV-UED-2024-0006782, STK-CV-UED-2024-0007321, STK-CV-UED-2024- 0006905,STK-CV-UED-2024- 000694, STK-CV-UED-2024- 0006781, STK-CV-UED-2024- 0006786, STK-CV-UED-2024- 0006783, STK-CV-UED-2024- 0006833, STKK-CV-UED- 2024, STK-CV-UED-2024- 0006836, STK-CV-UED-2024- 0006838& STK-CV-UED- 2024-0006900; Alameda Super. Ct. No. 24CV079864; Contra Costa Super. Ct. Nos. C24-01552 & C24-01489)

1 APPEAL from a judgment of the Superior Court of San Joaquin County, Lydia M. Villarreal, Judge. Affirmed. Nomellini, Grilli & McDaniel Law Office, Dante J. Nomellini, Jr., for Appellants. Rob Bonta, Attorney General, Iveta Ovsepyan, Assistant Attorney General, Molly S. Murphy, and Michael C. Gasbarro, Deputy Attorneys General, for Respondent State of California, acting by and through the Department of Water Resources.

This appeal arises from a series of petitions the Department of Water Resources (DWR) has filed seeking access to properties to investigate their suitability for a potential water conveyance project. DWR filed the petitions pursuant to Code of Civil Procedure 1 section 1245.010, et seq. (the precondemnation entry statutes), a statutory procedure by which “any person authorized to acquire property for a particular use by eminent domain” may obtain a court order to “enter upon property to make photographs, studies, surveys, examinations, tests, soundings, borings, samplings, or appraisals or to engage in similar activities reasonably related to acquisition.” (§ 1245.010.) In a prior appeal in this proceeding, the California Supreme Court held that the precondemnation entry statutes are a constitutionally valid procedure by which a public entity with eminent domain powers may enter property to conduct precondemnation testing and examination, so long as the landowner may obtain a jury trial on the measure of damages. (Property Reserve, Inc. v. Superior Court (2016) 1 Cal.5th 151, 167 (Property Reserve I).) The California Supreme Court held that a “classic” condemnation action—commenced by the filing of a complaint under section 1250.110 et seq.—is not required for precondemnation entry and testing, even if such activities rise to the level of a taking or damaging of property under the state takings clause. (Property Reserve I, at pp. 197-199.)

1 Undesignated section references are to the Code of Civil Procedure.

2 Notwithstanding Property Reserve I, appellant landowners contend that Water Code sections 250 and 11580 impose a special “timing limitation” (boldface & italics omitted) on DWR’s exercise of its eminent domain powers, requiring DWR to have an “authorized and funded project” in place before DWR may “commence any such proceeding in eminent domain.” (Wat. Code, § 250; see Wat. Code, § 11580.) We disagree. We conclude, as did our Supreme Court, that the precondemnation entry statutes provide a constitutionally valid procedure by which a public entity considering condemnation of property for a public project may enter the property and conduct investigatory testing and exploration necessary to determine whether the property is suitable for such purpose. (Property Reserve I, supra, 1 Cal.5th at pp. 167, 190, 198, 207, 212-213.) DWR need not commence a classic condemnation action, or comply with the “authorization and funding” requirements of Water Code sections 250 and 11580, before conducting precondemnation testing activities, irrespective of whether the activities will result in a taking or damaging of property. To conclude otherwise would be inimical to the purpose of the precondemnation entry and testing procedure, which is designed to “enable the public entity to determine whether or not the property is suitable and should be acquired for a public project.” (Property Reserve I, at p. 197.) Accordingly, we affirm the trial court’s entry order. BACKGROUND LEGAL PRINCIPLES A. Constitutional Takings Clause The federal takings clause, contained in the Fifth Amendment to the United States Constitution, provides: “[N]or shall private property be taken for public use, without just compensation.” (U.S. Const., 5th Amend.) It applies to the states through the Fourteenth Amendment. (Property Reserve I, supra, 1 Cal.5th at p. 185.) The law imposes two conditions on a state’s authority to confiscate private property—that the taking be for a “ ‘public use’ ” and that “ ‘just compensation’ ” be paid. (Council of San Benito County Governments v. Hollister Inn, Inc. (2012) 209 Cal.App.4th 473, 493 (San Benito).)

3 California’s takings clause is found in article I, section 19 of the California Constitution. It provides: “Private property may be taken or damaged for a public use . . . only when just compensation, ascertained by a jury . . . , has first been paid to, or into court for, the owner. The Legislature may provide for possession by the condemnor following commencement of eminent domain proceedings upon deposit in court and prompt release to the owner of money determined by the court to be the probable amount of just compensation.” (Cal. Const., art. I, § 19, subd. (a).) The California takings clause affords broader protection than its federal counterpart by (1) explicitly providing compensation for “damage” as well as a taking, (2) affording owners the right to a jury trial, and (3) requiring that the payment of compensation generally precede the taking or damaging of property. (Property Reserve I, supra, 1 Cal.5th at pp. 187-188; see NJD, Ltd. v. City of San Dimas (2003) 110 Cal.App.4th 1428, 1434.) Aside from these differences, the California Supreme Court has construed the state and federal clauses congruently. (Bottini v. City of San Diego (2018) 27 Cal.App.5th 281, 311, review granted Dec. 19, 2018 (S252217), review dismissed as improvidently granted Apr. 10, 2019.) Both the state and federal takings clause guarantee property owners “just compensation” when their private property is taken for public use. (Property Reserve I, at p. 185; Herzberg v. County of Plumas (2005) 133 Cal.App.4th 1, 12.) B. California’s Eminent Domain Law “In 1975, as the culmination of a multiyear effort to update and reorganize California’s eminent domain statutes into a comprehensive statutory scheme, the Legislature enacted a new, lengthy, and detailed Eminent Domain Law.” (Property Reserve I, supra, 1 Cal.5th at p. 183, citing Stats. 1975, ch. 1275, §§ 1–5, pp. 3409– 3466.) The Eminent Domain Law governs acquisitions by eminent domain except as otherwise specifically provided by statute. (§ 1230.020.) Thus, unless a different statute specifically overrides its provisions, the Eminent Domain Law governs the rules and

4 procedures for all eminent domain proceedings. (Cal. Law Revision Com. com., Deering’s Ann. Code Civ. Proc. (Lexis Advance) foll. § 1230.020 (Cal. Law Revision Com.); Conservatorship of Wendland (2001) 26 Cal.4th 519, 542 [explanatory comments by law revision commission are persuasive evidence of Legislature’s intent].) 1. A “Classic” Eminent Domain Proceeding To avoid confusion, we will follow the California Supreme Court’s lead in referring to an eminent domain proceeding commenced by the filing of a complaint under section 1250.110 et seq. as a “classic” condemnation proceeding, and the judicial proceeding provided by the precondemnation entry statutes (discussed below) as a “precondemnation” proceeding. (See Property Reserve I, supra, 1 Cal.5th at p.

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Dept. of Water Resources Cases, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dept-of-water-resources-cases-calctapp-2026.