Rainey v. Nevada Irrigation District CA3

CourtCalifornia Court of Appeal
DecidedJanuary 14, 2026
DocketC102948
StatusUnpublished

This text of Rainey v. Nevada Irrigation District CA3 (Rainey v. Nevada Irrigation District CA3) 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
Rainey v. Nevada Irrigation District CA3, (Cal. Ct. App. 2026).

Opinion

Filed 1/14/26 Rainey v. Nevada Irrigation District CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

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

MICHAEL RAINEY et al., C102948

Plaintiffs and Appellants, (Super. Ct. No. CU19084309)

v.

NEVADA IRRIGATION DISTRICT,

Defendant and Respondent.

Michael Rainey and Emerson Pachaud (collectively plaintiffs) sued the Nevada Irrigation District (District) for inverse condemnation, private nuisance, and dangerous condition of public property, seeking damages for landslides allegedly resulting from water leaking and/or seeping from an irrigation ditch. The trial court granted the District’s motion for summary adjudication as to Rainey’s nuisance and dangerous condition claims on statute of limitations grounds and bifurcated the trial into two phases: in the first phase, the trial court would conduct a bench trial addressing liability as to the

1 inverse condemnation claim; and, in the second phase, a jury would consider the question of inverse condemnation damages and Pachaud’s remaining claims. In the bench trial phase, the trial court found in favor of the District on inverse condemnation liability. The District then moved for judgment on the pleadings, arguing the trial court’s finding that the District’s irrigation ditch did not cause or contribute to the landslide damage on plaintiffs’ properties was conclusive as to Pachaud’s remaining claims. The trial court granted the motion and entered judgment in favor of the District. On appeal, Pachaud1 argues the trial court erred by granting the District’s motion for judgment on the pleadings because the bifurcation order misleadingly or ambiguously stated that Pachaud’s nuisance and dangerous condition claims would be decided by a jury and the bench trial ruling thus was not binding as to those claims. (Citing Darbun Enterprises, Inc. v. San Fernando Community Hospital (2015) 239 Cal.App.4th 399 (Darbun).) We disagree and affirm. BACKGROUND Plaintiffs have neighboring properties located downhill from an irrigation ditch maintained, managed, operated, and owned by the District. Plaintiffs sued the District for inverse condemnation, private nuisance, and dangerous condition of public property, generally alleging: the District’s irrigation ditch leaked water onto their properties; around the same time, subsurface water began seeping out of banks on their properties; the District attempted to fix the leak to no avail; water continues to leak/seep onto their properties; and the water has caused landslides on their land. The District filed a motion for summary judgment or, in the alternative, summary adjudication, and a motion to bifurcate the trial. In December 2023, the trial court issued

1 As explained post, we grant the District’s motion to strike Rainey as a party to this appeal because he is not aggrieved by the trial court’s ruling on the motion for judgment on the pleadings.

2 a memorandum decision and order denying the District’s motion for summary judgment and granting and denying in part its motions for summary adjudication and bifurcation. As pertinent here, the trial court granted the motion for summary adjudication as to Rainey’s nuisance and dangerous condition claims on statute of limitations grounds. The trial court further granted the motion to bifurcate the liability phase of the inverse condemnation claim from “the remaining claims and issues (inverse condemnation damages, nuisance and dangerous condition claims to be heard by the jury).” The trial court explained: “Resolution of the first liability claim in a bench trial will allow the Court to make a well-informed decision as to liability and will allow the Court and the parties to identify the scope of the issues that remain for potential jury resolution during the second phase in light of the Court’s findings and conclusions. Moreover, resolution of the first claim will provide the parties with valuable information to inform their judgment as to whether they wish to resolve the matter or exercise their rights to a jury trial.” In August 2024, in the bench trial phase, the trial court issued a statement of decision in favor of the District on inverse condemnation liability. One basis for the trial court’s no liability finding was that the plaintiffs had failed to establish by a preponderance of the evidence that the “leakage/seepage was a substantial cause of their landslide property damage.” The trial court explained that it “carefully considered all direct and circumstantial evidence offered by the parties regarding alleged leakage/seepage/water escaping from the canal and causation of damages related thereto (including, but not limited to, all expert and lay testimony)” and “found that the evidence adduced by plaintiffs was unpersuasive and entitled to minimal, at best, weight.” The District then filed a motion for judgment on the pleadings, arguing the trial court’s finding that plaintiffs had failed to establish causation as to the inverse condemnation claim was dispositive of Pachaud’s remaining claims. The trial court granted the motion, explaining Pachaud could not state a cause of action for nuisance or

3 dangerous condition, both of which require a showing of causation, because the trial court’s lack of causation finding in the equity phase was binding in any subsequent jury trial. (Citing Bookout v. State of California ex rel. Dept. of Transportation (2010) 186 Cal.App.4th 1478, 1481, 1488; McCorkle v. State Farm Ins. Co. (1990) 221 Cal.App.3d 610, 616.) The trial court further found Darbun, supra, 239 Cal.App.4th 399 inapplicable because “the court made it clear in its decision granting bifurcation that it would decide the issue of liability in connection with the inverse condemnation claim, which expressly and necessarily included the issue of causation.” Plaintiffs filed a joint notice of appeal challenging the ruling on the motion for judgment on the pleadings. DISCUSSION I The Motion to Strike Is Granted The District filed an uncontested motion to strike Rainey as an appellant, asserting he lacks standing because he is not aggrieved by the motion for judgment on the pleadings ruling that is the subject of this appeal. The District explains: when the trial court issued the bifurcation ruling, it also granted summary adjudication against Rainey with respect to his nuisance and dangerous condition claims on statute of limitations grounds; the trial court thereafter held the bench trial and found in favor of the District on Rainey’s inverse condemnation claim; and, accordingly, all three of Rainey’s claims were fully adjudicated when the District filed the motion for judgment on the pleadings as to Pachaud’s nuisance and dangerous condition claims. We agree with the District and strike Rainey as a party to the appeal. (Dow v. Lassen Irrigation Co. (2022) 75 Cal.App.5th 482, 488 [only a party “ ‘whose rights or interests are injuriously affected’ ” by the order has standing to appeal it]; see Santos v. El Guapo Tacos, LLC (2021) 72 Cal.App.5th 363, 368 [plaintiff not aggrieved by the order on appeal lacked standing to prosecute the appeal].)

4 II The Judgment Is Affirmed A case generally may involve legal claims (e.g., claims relating to property rights, debts, and trespasses decided by a jury) and/or equitable claims (e.g., claims dealing with ethical matters decided by a judge). (Hoopes v. Dolan (2008) 168 Cal.App.4th 146, 155.) Complications arise when legal and equitable claims are asserted in a single lawsuit.

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Cite This Page — Counsel Stack

Bluebook (online)
Rainey v. Nevada Irrigation District CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rainey-v-nevada-irrigation-district-ca3-calctapp-2026.