San Luis Unit Food Producers v. United States

709 F.3d 798 (2013)

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San Luis Unit Food Producers v. United States

United States Court of Appeals for the Ninth Circuit
709 F.3d 798 (2013)

Facts

The United States Bureau of Reclamation (the bureau) (defendant) had control over reclamation-project water distribution within the Central Valley Project (CVP) in California under the Reclamation Act of 1902 and various federal and state statutory progeny. One of the distribution projects in the CVP was known as the San Luis Project. After years of receiving 100 percent of the water needed for irrigation, farmers served by the San Luis Project, including San Luis Unit Food Producers (collectively, the farmers) (plaintiffs), started receiving less than their full historical allotment of irrigation. This condition arose because the bureau had shifted its approach to serve more environmental purposes, including fish and wildlife preservation. The farmers sued the bureau in the United States District Court for the Eastern District of California under the Administrative Procedure Act (APA), asserting that numerous state and federal statutes required the bureau to fully provide for their irrigation needs before diverting water for other purposes. Claiming that the bureau had a mandatory duty to deliver the water it had failed to satisfy, the farmers sought an order compelling the bureau to deliver the needed water. The district court granted summary judgment in favor of the bureau for, among other reasons, the farmers’ failure to satisfy the APA’s requirement for final agency action. The farmers appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Trott, J.)

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