AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The La Madera Community Ditch Association and two of its water users alleged that Sandia Peak Ski Company trespassed upon and impaired their senior water rights in the La Madera watershed. They claimed their water rights dated back to 1855 and sought to enjoin Sandia Peak from using its junior water rights to interfere with their usage (paras 2-3).

Procedural History

• District Court, January 4, 1994: The district court dismissed La Madera's petition for trespass, ruling that all water users in the stream system were indispensable parties and needed to be joined. The court allowed La Madera 45 days to amend its petition to include all such parties, but La Madera declined to do so, leading to the dismissal of the case (paras 3, 16).

Parties' Submissions

• Appellants (La Madera Community Ditch Association and others): Argued that their case was a simple trespass action involving only the two parties and did not require a full stream adjudication or the joinder of all other water users. They contended that the district court could determine their water rights and Sandia Peak's alleged trespass without affecting other water users (paras 4, 6-7).
• Respondent (Sandia Peak Ski Company): Asserted that under New Mexico law, all claimants to the use of water in a stream system must be joined in any action determining water rights. They argued that this requirement avoided piecemeal litigation and ensured that all affected parties were bound by the court's decision (paras 3, 5).

Legal Issues

• Was La Madera required to seek a full stream adjudication and join all other water users as indispensable parties before the district court could consider its trespass claim? (paras 1, 4).

Disposition

• The Court of Appeals reversed the district court's dismissal and remanded the case with instructions to reinstate it and allow for the joinder of junior appropriators if Sandia Peak demonstrated their relevance to the case (para 16).

Reasons

Per Flores J. (Donnelly and Pickard JJ. concurring):

• The court held that La Madera's trespass claim did not require a full stream adjudication or the joinder of all water users. It distinguished between actions seeking to adjudicate water rights for an entire stream system and those involving disputes between specific parties (paras 6-7).
• The court emphasized that the determination of La Madera's water rights and Sandia Peak's alleged trespass would only bind the parties to the case and not affect other water users. Requiring joinder of all water users would impose an unreasonable burden on plaintiffs in simple trespass cases (paras 7, 11-12).
• The court rejected Sandia Peak's reliance on prior cases like City of Albuquerque v. Reynolds and State ex rel. Reynolds v. W.S. Ranch Co., finding them distinguishable. It instead relied on Chavez v. Gutierrez, which allowed trespass actions to proceed without full stream adjudications (paras 8-11).
• The court acknowledged Sandia Peak's concern about potential multiplicity of actions but placed the burden on Sandia Peak to identify junior appropriators whose joinder might be necessary to mitigate its liability. If such appropriators existed, they could be joined; otherwise, the case could proceed without them (paras 15-16).