Hall v. Springville City

The Utah Court of Appeals recently issued its opinion in the case of Hall v. Springville City. This case focuses on Springville City's ownership claims to water rights that were included in the Proposed Determination for the Hobble Creek area. 

The case concerns water rights that were originally associated with the Anderson Ranch and Clark Ranch in Hobble Creek Canyon. The ranches were homesteaded in the late 1800s, and water rights were established by diligence (i.e., by diversion and use of surface water prior to 1903). In 1928, the Springville Irrigation Company was formed, and the Andersons and Clarks conveyed irrigation water rights to the Company in exchange for water shares. In the 1940s, the City determined to buy water rights in Hobble Creek Canyon in order to expand its water system to serve its growing population. The City acquired the Anderson Ranch and the Clark Ranch, along with all water rights and all Company water shares associated with the ranches. A few years later, the City sold the ranches to Ralph Phillips. The land deed noted that "All water and water rights heretofore used on the aforesaid granted premises have been separately sold and transferred and this conveyance is made subject to the reservation of all water rights excepting only a flood water right to which the cultivated or improved part of the aforesaid granted premises shall be entitled when and as long as such flood water is available." The City and Mr. Phillips subsequently entered into agreements allowing Mr. Phillips to use the water rights and water shares until the City needed the water for its own purposes.

Decades later, the subsequent owners of the ranches filed Diligence Claims and Water Users Claims asserting year-round rights from springs for irrigation, domestic, and stockwatering purposes. These asserted water rights were included in the Proposed Determination published in 1986. The City filed objections to the Proposed Determination, asserting that the water rights were invalid because (among other things) the City was "the owner of the entire flow of water from the sources given" for the water rights. 

In 2020, the City filed motions for summary judgment on its objection, in which the City sought to have the district court declare the water rights invalid because the landowners' predecessors had deeded all water rights to the City in the 1940s. The landowners opposed the motions and argued, among other things, that the "flood water" language in the 1940s deed gave them a legitimate basis for their water rights. The Special Master ruled in the City's favor, which the district court later confirmed. The landowners appealed the case to the Utah Court of Appeals.

The Court began its opinion by determining that when the City acquired title to the ranches, the City also acquired all water rights and all water shares. The Court then examined the "flood water" language from the 1940s deed and determined that the language did not convey any water rights from the City to Mr. Phillips but, instead, granted Mr. Phillips the ability to take advantage of any natural flooding that occurred; i.e., any water that naturally escaped the stream channel during periods of high flow. The Court further noted that even if the interpretation of "flood water" was ambiguous, the extrinsic evidence supported the City's assertion that it did not convey any water rights to Mr. Phillips. Additionally, the Court noted that the Utah Constitution prohibits municipalities from selling or conveying away its water rights, which further confirms that the City did not convey any water rights to Mr. Phillips. Finally, the Court disagreed with the landowners' assertion that the City and Mr. Phillips entered into an exchange of water rights.

The Court also examined the landowners' claim that they had been denied due process rights because they had not been given "adequate notice" of the City's claims of ownership of the water rights. The Court determined that the City's objection was satisfactory under the relevant statutes at the time and that the landowners were given sufficient opportunity to engage in discovery and litigate the relevant issues in the adjudication. 

Based on these determinations, the Court of Appeals affirmed the district court's decision that the water rights were invalid.

(The attorneys at Smith Hartvigsen were proud to represent Springville City in this case.)

To read the full opinion, click here.