Andrus v. Charlestone Stone Products Co.
56 L. Ed. 2d 570, 436 US 604, 1978 U.S. LEXIS 99 (1978)
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Rule of Law:
Water is not a 'valuable mineral' as defined by the Mining Law of 1872 and is therefore not a locatable substance that can form the basis of a valid mining claim on federal lands. Water rights on federal lands are governed by state and local laws of appropriation, a system Congress intended to keep separate from the federal mineral patenting system.
Facts:
- In 1942, a group of 23 mining claims were established on federal land near Las Vegas, Nevada.
- Charlestone Stone Products Co. subsequently purchased these claims.
- In 1962, Charlestone drilled a well on one of the claims, known as Claim 22, and discovered a source of water.
- Charlestone used the water from Claim 22 to process sand and gravel that it was extracting from its other mining claims in the area.
Procedural Posture:
- In 1965, the Secretary of the Interior filed an administrative complaint with the Bureau of Land Management to declare Charlestone's mining claims invalid.
- An Administrative Law Judge held that only one of the primary claims was valid.
- On appeal, the Interior Board of Land Appeals (IBLA) affirmed the Administrative Law Judge's decision.
- Charlestone sought judicial review of the IBLA's decision in the U.S. District Court for the District of Nevada.
- The District Court reversed the IBLA, finding several claims valid and holding that Charlestone was entitled to access the water on Claim 22 to support its mining operations.
- The Government, as appellant, appealed the District Court's decision to the U.S. Court of Appeals for the Ninth Circuit, with Charlestone as appellee.
- The Court of Appeals affirmed but did so on the novel rationale that Claim 22 was itself a valid mining claim because water is a 'valuable mineral' under the 1872 mining law.
- The Government then petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does water qualify as a 'valuable mineral' making it locatable under the Mining Law of 1872?
Opinions:
Majority - Mr. Justice Marshall
No. Water is not a 'valuable mineral' locatable under the Mining Law of 1872. The term 'mineral' in the statute cannot be interpreted in its broadest literal sense, which would encompass nearly all land; instead, congressional intent is paramount. The history of federal mining legislation, including the Acts of 1866, 1870, and 1872, demonstrates that Congress intended to create two distinct legal systems: a comprehensive federal regime for mineral rights and a separate system for water rights that defers to state and local laws of appropriation. To hold that water is a locatable mineral would create a conflicting parallel federal system for water rights, undermining the established state-based appropriation doctrines prevalent in the West and leading to significant practical and legal problems. This interpretation is reinforced by the canon of construction that resolves any doubts in grants of federal land in favor of the government.
Analysis:
This decision solidifies the long-standing separation between federal mineral law and state-based water law in the American West. It prevents the use of federal mining claims as a backdoor to acquire valuable water rights, which would disrupt the established prior appropriation doctrine that governs water allocation in arid states. The ruling reaffirms that Congress intended two distinct legal regimes for these resources and prevents the legal chaos that would ensue from their conflation. It thereby protects state authority over water resources and prevents abuse of the federal mining laws for purposes unrelated to traditional mining.
