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Agua Caliente Band of Cahuilla Indians v. Coachella Valley Water District

849 F.3d 1262 · 2017 · United States Court of Appeals for the Ninth Circuit

Holding

The Ninth Circuit held that the Winters doctrine does not distinguish between surface water and groundwater: when the United States established the Agua Caliente Reservation in the arid Coachella Valley it impliedly reserved appurtenant water sources, including the groundwater of the Coachella Valley aquifer, and that federal reserved right preempts conflicting state water rights and survives the Tribe's historical non-use.

"When the well's dry, we know the worth of water" — Benjamin Franklin, as quoted at the opening of the Ninth Circuit's opinion (Tallman, J.)

Why it matters for settlements

First federal appellate holding squarely extending tribal reserved water rights to groundwater, a pressure point for basins where surface supplies are fully appropriated.

Read the primary record (courtlistener.com)

Interlocutory appeal, Phase I of trifurcated litigation (existence of the groundwater right only). Same CourtListener HTML interstitial caveat.

Sources

CourtListener search API (citation 849 F.3d 1262, dateFiled 2017-03-07, court, canonical URL, opinion opening) (courtlistener.com, retrieved 2026-09-01)
Justia (docket 15-55896, decided 2017-03-07, court description of the holding; cross-check) (law.justia.com, retrieved 2026-09-01)