United States v. Black Canyon Irrigation District, State of Idaho, and Suez Water Idaho, Inc.

Summary

The Idaho Supreme Court affirmed a district court judgment holding that the United States’ late-filed supplemental storage water-right claims were barred by claim preclusion. The court concluded that the relevant water rights had been adjudicated and decreed in prior general adjudications, that the claims arose from the same transaction, and that they should have been asserted earlier. The court also rejected the United States’ argument that later changes in water-accounting procedures created claims exempt from preclusion.

Holdings

1. Claim preclusion barred the United States from litigating the late claims because the Payette Adjudication and SRBA were final judgments on the merits, the identity-of-parties requirement was satisfied or had little relevance in the general-adjudication context, and the late claims arose from the same transaction and should have been asserted in the earlier adjudications.
2. The State and Suez were prevailing parties but were not entitled to attorney fees because the United States had not acted without a reasonable basis in fact or law.

Questions Presented

1. Whether claim preclusion barred the United States' late claims for supplemental beneficial-use storage water rights.
2. Whether the State of Idaho and Suez Water Idaho, Inc. were entitled to attorney fees on appeal under Idaho Code section 12-117.

Disposition

affirmed