Franco-American Charolaise, Ltd. v. Oklahoma Water Resources Board

1990 OK 44, 855 P.2d 568, 1990 Okla. LEXIS 49, 1990 WL 50192
CourtSupreme Court of Oklahoma
DecidedApril 24, 1990
Docket59310
StatusPublished
Cited by19 cases

This text of 1990 OK 44 (Franco-American Charolaise, Ltd. v. Oklahoma Water Resources Board) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franco-American Charolaise, Ltd. v. Oklahoma Water Resources Board, 1990 OK 44, 855 P.2d 568, 1990 Okla. LEXIS 49, 1990 WL 50192 (Okla. 1990).

Opinions

OPALA, Justice.

This appeal challenges the constitutionality of the 1963 amendments to Oklahoma’s water law insofar as the amendments regulate riparian rights.2 The case also raises a first-impression question about the interpretation of the requirements for perfecting an appropriative right under 82 O.S. 1981 § 105.12.3 We affirm the trial court’s findings of fact, holding that they are supported by substantial evidence.4 The questions of law tendered for our resolution are:

1. What is the nature of the riparian right under Oklahoma common law?
2. To what extent did the 1963 amendments abrogate the common-law riparian right?
3. Are the 1963 amendments constitutional when measured by Art. 2, § 24 Okl. Const.?
4. Does 82 O.S.1981 § 105.12(2) require consideration of an applicant’s available groundwater in determining its need for stream water?
5. Does 82 O.S.1981 § 105.12(4) require that an out-of-basin appropriation be granted subject to recall by in-basin [571]*571riparian owners and appropriative users?

We hold that the Oklahoma riparian owner enjoys a vested common-law right to the reasonable use of the stream. This right is a valuable part of the property owner’s “bundle of sticks” and may not be taken for public use without compensation.5 We further hold that, inasmuch as 60 O.S.1981 § 60, as amended in 1963, limits the riparian owner to domestic use and declares that all other water in the stream becomes public water subject to appropriation without any provision for compensating the riparian owner, the statute violates Art. 2 § 24, Okl. Const.

In addition, we declare that the California Doctrine of stream water rights,6 which recognizes riparian and appropriative rights as coexistent, is the prevailing law in Oklahoma; that the Oklahoma Water Resources Board [OWRB] may, in its discretion, find that an applicant for an appropriation has a need for stream water without regard to any claimed or perfected groundwater sources; that a perfected appropria-tive right is a vested right which may not be permanently divested except for nonuse after notice and hearing but is subject to senior appropriative rights and reasonable riparian uses during shortages; and that in the future a riparian owner seeking an appropriation of stream water must be deemed to have voluntarily relinquished his riparian rights in that stream water except for those preserved under the statute for domestic uses.

A. STATEMENT OF THE FACTS

Mill Creek is a spring-fed dry weather creek in the.Upper Clear Boggy watershed within the Muddy Boggy River Basin. Byrd’s Mill Spring flows directly into Mill Creek which in turn flows into Clear Boggy Creek. Clear Boggy Creek is joined by Buck Creek and flows downstream as Clear Boggy Creek where it joins Muddy Boggy Creek to form the Muddy Boggy River. The latter is a tributary of the Red River. In 1980 the area experienced a severe drought and the stream bed in Clear Boggy Creek went dry. In August of 1980 the City of Ada [City] made application, pursuant to 82 O.S.1981 § 105.9, to increase its appropriation of water from Byrd’s Mill Spring from 3,360 acre feet per year to 11,202 acre feet per year to meet a projected annual need of 10,523 acre feet per year by the year 2020. The City straddles two watersheds with approximately 80 percent in the South Canadian Stream Basin and 20 percent in the Clear Boggy Stream Basin. Riparian owners and in-basin appropriators objected to the City’s application for additional stream water. The OWRB determined that the average yield of Byrd’s Mill Spring is 9,820 acre feet per year. Prior appropriations, including that of the City and some appellee riparian owners, total 3,776 acre feet per year. Allowing 584 acre feet to supply domestic needs down to Buck Creek and 120 acre feet for unavoidable loss, the OWRB found the amount available for appropriation was 5,340 acre feet, 2,502 acre feet less than the 7,842 acre feet requested by the City. The City amended its application to conform to the finding. The OWRB then granted all 5,340 acre feet available for appropriation to the City, requiring the City to release at least 1,120 acre feet of water per year downstream. The OWRB order also required the City to meter and record monthly the amount of water taken from Byrd’s Mill Spring. In-basin riparian owners and appropriators appealed from the administrative decision to the District Court, Coal County.7

[572]*572B. COMMON-LAW AND STATUTORY AUTHORITY AFFECTING WATER RIGHTS

The Organic Act of 18908 extended England’s common law over Indian Territory. The same year the Territorial Legislature adopted a statute declaring the nature of water rights in the Territory:

“The owner of land owns water standing thereon, or flowing over or under its surface, but not forming a definite stream. Water running in a definite stream, formed by nature over or under the surface may be used by him as long as it remains there; but he may not prevent the natural flow of the stream, or of the natural spring from which it commences its definite course, nor pursue nor pollute the same.” 9

This codification of the common-law riparian doctrine of water rights remained the law in Oklahoma until legislative adoption of the 1963 amendments.

In 1897 the legislature provided for the appropriation of the ordinary flow or underflow of stream water for the irrigation of arid sections of the State.10 The statute protected the riparian owner from the appropriation of the ordinary flow of the stream without the riparian owner’s consent except by condemnation.11 In 1905 the provision protecting the riparian right was omitted.12 It was reinstated in 1909, then finally eliminated in 1910.13 In 1925 the legislature added a provision recognizing the priority of all beneficial uses of water initiated prior to statehood.14

Since 1897 both the common law and the statutes have operated in Oklahoma to confer riparian and appropriative rights. Though these rights have coexisted in the State for almost 100 years, they are theoretically irreconcilable.15 The common-law riparian right extends to the reasonable use of the stream or to its natural flow, depending on the jurisdiction; the appropri-ative right attaches to a fixed amount. The last riparian use asserted has as much priority as the first; the appropriator who takes first has the senior right. In 1963 [573]*573the legislature attempted to reconcile the two doctrines. The amendments, shown in italics, are as follows:

“The owner of the land owns water standing thereon, or flowing over or under its surface but not forming a definite stream. The use of groundwater shall be governed by the Oklahoma Ground Water Law. Water running in a definite stream, formed by nature over or under the surface, may be used by him for domestic purposes as defined in Section 2(a) of this Act,

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Franco-American Charolaise, Ltd. v. Oklahoma Water Resources Board
1990 OK 44 (Supreme Court of Oklahoma, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
1990 OK 44, 855 P.2d 568, 1990 Okla. LEXIS 49, 1990 WL 50192, Counsel Stack Legal Research, https://law.counselstack.com/opinion/franco-american-charolaise-ltd-v-oklahoma-water-resources-board-okla-1990.