Supreme Court of the United States
State of Arizona v. State of California Bill of Complaint
October 10, 2000531 U.S. 1
Summary
The Court held that the United States and the Quechan Tribe were not barred from seeking additional water rights for disputed Fort Yuma Reservation boundary lands. The State parties forfeited their preclusion defense by failing to raise it despite earlier opportunities, and the later consent judgment did not establish issue preclusion because the underlying ownership issue was neither litigated nor decided and the settlement covered mutually exclusive theories. The Court approved settlements concerning the Fort Mojave and Colorado River Reservations and remanded the Fort Yuma claims for determination on the merits.
Holding
- Preclusion based on the earlier water-rights judgment. The Fort Yuma additional-water claims were not foreclosed because the State parties forfeited their preclusion defense by failing to raise it at earlier stages despite ample opportunity and incentive to do so.
- Issue preclusion based on the consent judgment. The consent judgment did not preclude the Fort Yuma additional-water claims because it had claim-preclusive effect between the original parties but did not establish issue preclusion.
- Approval of settlements for the Fort Mojave and Colorado River Reservations. The Court approved the parties' proposed settlements resolving the additional-water disputes concerning the Fort Mojave and Colorado River Reservations.
Docket 8 ORIG
Cited authorities
- Rule 8(c)
- 43 U.S.C. § 617
- 60 Stat. 1049
- 25 U.S.C. § 70
- 13 Stat. 541
- Fed. R. Civ. P. 8(c)
- 13 Stat. 541