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 case revolves around a dispute concerning the ownership of a groundwater right on approximately twenty-eight acres of elevated bench lands on a farm property in Salem, New Mexico. The Office of the State Engineer (OSE) initiated a subfile proceeding to determine the ownership of water rights on the farm, which was divided into valley lands and bench lands for the proceeding. The dispute specifically targeted the right to groundwater produced from a well for the upper sixteen benches on the property. Over four years, the OSE made several offers of judgment to reach an agreement on this disputed water right, but no agreement was reached, leading to the appointment of a special master to try the matter (paras 1-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Office of the State Engineer (OSE): Argued that a water right was never established for the disputed benches because water from the well was not put to beneficial use on these benches. Alternatively, claimed that any water right that may have once existed on the disputed benches had been abandoned (para 6).
• John D. Baca: Contended that irrigation groundwater rights were established on the disputed benches and that he had not abandoned this water right (para 7).

Legal Issues

• Whether a predecessor in interest to Baca established a groundwater right on the disputed benches and, if so, whether Baca abandoned this water right (para 6).

Disposition

• The district court's order declaring that Baca did not have a water right on the disputed bench lands was reversed, and the case was remanded for the district court to consider the OSE’s remaining objection on the issue of abandonment of the water right (para 30).

Reasons

• The Court of Appeals, with Judge Cynthia A. Fry authoring the opinion, found that the district court improperly disregarded the special master's report, which recommended granting ownership of the disputed water right to Baca. The district court was found to have improperly re-weighed evidence and applied an erroneous standard of review in rejecting the special master’s report. The appellate court clarified that the district court could reject the special master’s findings of fact only if they were not supported by substantial evidence. The appellate court agreed with Baca that the district court was bound by the factual findings entered by the special master because the findings were supported by substantial evidence. The appellate court concluded that the district court erred in setting aside the special master’s finding of beneficial use, which was based on evidence of crop growth on the disputed bench lands. The appellate court reversed the district court’s order and remanded the case for further proceedings on the issue of abandonment of the water right (paras 9-30).