County of San Joaquin v. State Water Res. Control Bd.

In this dispute, established water users challenge restrictions imposed under new federal standards for water quality and wildlife protection. The trial court found the United States Bureau of Reclamation was an indispensable party and dismissed the action after the bureau refused to waive its sovereign immunity. The plaintiffs appeal on equitable grounds; we affirm.

Factual and Procedural Background

The United States Bureau of Reclamation (Bureau) operates the Central Valley Project, the country’s largest water reclamation project. “The Sacramento Valley, containing the Sacramento River, lies in the northern portion of the Central Valley, and the San Joaquin Valley, containing the San Joaquin River, lies in the southern portion. The Sacramento River has a surplus of water because of heavier rainfall in the northern region .... The San Joaquin River, in contrast, does not supply sufficient water for the extensive amount of tillable soil in its valley. The [Central Valley Project] transports some of the Sacramento River’s surplus water to the San Joaquin Valley and permits the waters of the San Joaquin River to be diverted for irrigation and other purposes to new areas…