appropriation doctrine (Washington) · Go Syfert
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appropriation doctrine in Washington

15 Washington opinions name it 3 courts 1991–2025 1 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Department of Ecology v. Campbell & Gwinn, L.L.C.green
wash · 2002 · cited in 7 Washington opinions naming this issue, 2009–2025
2 sentences

2016Thus, it is subject to the basic principle of water rights acquired, by prior appropriation that the first in time is the first in right. 146 Wn.2d 1, 9 , 43 P.3d 4 (2002) (emphasis added); see also Campbell & Gwinn, 146 Wn.2d at 17 n.8 (“RCW 90.44.050 itself provides that a right acquired under the exemption is to be treated as all other rights, and thus is subject to the prior appropriation doctrine’s first in time first in right principle.”). 5 ¶12 The court reiterated this point in Swinomish Indian Tribal Community v. Department of Ecology, 178 Wn.2d 571 , 311 P.3d 6 (2013), where it addre

2016Thus, it is subject to the basic principle of water rights acquired, by prior appropriation that the first in time is the first in right. 146 Wn.2d 1, 9 , 43 P.3d 4 (2002) (emphasis added); see also Campbell & Gwinn, 146 Wn.2d at 17 n.8 (“RCW 90.44.050 itself provides that a right acquired under the exemption is to be treated as all other rights, and thus is subject to the prior appropriation doctrine’s first in time first in right principle.”). 5 ¶12 The court reiterated this point in Swinomish Indian Tribal Community v. Department of Ecology, 178 Wn.2d 571 , 311 P.3d 6 (2013), where it addre

47
Postema v. Pollution Control Hearings Boardgreen
wash · 2000 · cited in 5 Washington opinions naming this issue, 2002–2015
2 sentences

2015Postema, 142 Wn.2d at 90 .

2013This “paramount rule” of the doctrine means that “ ‘[t]he first appropriator is entitled to the quantity of water appropriated by him, to the exclusion of subsequent claimants’ ” Postema, 142 Wn.2d at 80, 79 (emphasis added) (quoting Longmire , 26 Wash, at 447). 9 The prior appropriation doctrine and the first in time first in right priority principle are founded on the idea that at some point the water in a stream or lake will be insufficient to satisfy all potential users, and that the rights of those who have already appropriated water to a beneficial use will be superior to any later appro

15
Swinomish Indian Tribal Community v. Department of Ecologygreen
wash · 2013 · cited in 2 Washington opinions naming this issue, 2016–2019
2 sentences

2016Thus, it is subject to the basic principle of water rights acquired, by prior appropriation that the first in time is the first in right. 146 Wn.2d 1, 9 , 43 P.3d 4 (2002) (emphasis added); see also Campbell & Gwinn, 146 Wn.2d at 17 n.8 (“RCW 90.44.050 itself provides that a right acquired under the exemption is to be treated as all other rights, and thus is subject to the prior appropriation doctrine’s first in time first in right principle.”). 5 ¶12 The court reiterated this point in Swinomish Indian Tribal Community v. Department of Ecology, 178 Wn.2d 571 , 311 P.3d 6 (2013), where it addre

2016Thus, it is subject to the basic principle of water rights acquired, by prior appropriation that the first in time is the first in right. 146 Wn.2d 1, 9 , 43 P.3d 4 (2002) (emphasis added); see also Campbell & Gwinn, 146 Wn.2d at 17 n.8 (“RCW 90.44.050 itself provides that a right acquired under the exemption is to be treated as all other rights, and thus is subject to the prior appropriation doctrine’s first in time first in right principle.”). 5 ¶12 The court reiterated this point in Swinomish Indian Tribal Community v. Department of Ecology, 178 Wn.2d 571 , 311 P.3d 6 (2013), where it addre

12
State v. Pontengreen
wash · 1969 · cited in 1 Washington opinions naming this issue, 2016–2016
2 sentences

2016See State v. Ponten, 77 Wn.2d 463 , 463 P.2d 150 (1969); Welch v. Dep’t of Ecology, No. 98-108, 2000 WL 871699 , 2000 WA ENV LEXIS 109 (Wash. Pollution Control Hr’gs Bd. May 4, 2000).

2016See State v. Ponten, 77 Wn.2d 463 , 463 P.2d 150 (1969); Welch v. Dep’t of Ecology, No. 98-108, 2000 WL 871699 , 2000 WA ENV LEXIS 109 (Wash. Pollution Control Hr’gs Bd. May 4, 2000).

11
Fox v. Ickesgreen
cadc · 1943 · cited in 1 Washington opinions naming this issue, 1991–1991
1 sentence

1991Fox v. Ickes, 137 F.2d 30, 33 (D.C.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Hallauer v. Spectrum Properties, Inc. green
wash · 2001
2 sentences

2019The prior appropriation doctrine “‘provides that a right to water can be established only by putting water to beneficial use and that the first such use in time is the first such use in right.’” Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001) (quoting Charles B.

2010Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001); In re Surface Waters of Deadman Creek Drainage Basin, 103 Wn.2d 686 , 694 P.2d 1071 (1985); 23 Timothy Butlek & Matthew King, Washington Practice: Environmental Law and Practice § 8.2, at 288-89 (2d ed. 2007).

32010–2019
Hallauer v. Spectrum Properties, Inc. green
wash · 2001
2 sentences

2019The prior appropriation doctrine “‘provides that a right to water can be established only by putting water to beneficial use and that the first such use in time is the first such use in right.’” Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001) (quoting Charles B.

2010Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001); In re Surface Waters of Deadman Creek Drainage Basin, 103 Wn.2d 686 , 694 P.2d 1071 (1985); 23 Timothy Butlek & Matthew King, Washington Practice: Environmental Law and Practice § 8.2, at 288-89 (2d ed. 2007).

32010–2019
State, Dept. of Ecology v. Campbell & Gwinn green
wash · 2002
2 sentences

2025Dep’t of Ecology v. Campbell & Gwinn, L.L.C., 146 Wn.2d 1, 7 , 43 P.3d 4 (2002); see RCW 90.03.010.

2016Thus, it is subject to the basic principle of water rights acquired, by prior appropriation that the first in time is the first in right. 146 Wn.2d 1, 9 , 43 P.3d 4 (2002) (emphasis added); see also Campbell & Gwinn, 146 Wn.2d at 17 n.8 (“RCW 90.44.050 itself provides that a right acquired under the exemption is to be treated as all other rights, and thus is subject to the prior appropriation doctrine’s first in time first in right principle.”). 5 ¶12 The court reiterated this point in Swinomish Indian Tribal Community v. Department of Ecology, 178 Wn.2d 571 , 311 P.3d 6 (2013), where it addre

22016–2025
Richard A. Fox And Marnie B. Fox, Apps. v. Skagit County, Res. green
washctapp · 2016
2 sentences

2019Prior Appropriation Doctrine Washington follows the prior appropriation doctrine of water rights, summarized: “‘as between appropriations, the first in time shall be the first in right.’” Fox v. Skagit County, 193 Wn.

2019App. 254, 264 , 372 P.3d 784 (2016) (quoting RCW 90.03.010).

22016–2019
Longmire v. Smith green
wash · 1901
2 sentences

2013RCW 90.03.010; Campbell & Gwinn, 146 Wn.2d at 9 ; Postema, 142 Wn.2d at 79 ; Longmire v. Smith, 26 Wash. 439, 447 , 67 P. 246 (1901).

2013RCW 90.03.010; Campbell & Gwinn, 146 Wn.2d at 9 ; Postema, 142 Wn.2d at 79 ; Longmire v. Smith, 26 Wash. 439, 447 , 67 P. 246 (1901).

22013–2013
Department of Ecology v. Abbott green
wash · 1985
2 sentences

2010Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001); In re Surface Waters of Deadman Creek Drainage Basin, 103 Wn.2d 686 , 694 P.2d 1071 (1985); 23 Timothy Butlek & Matthew King, Washington Practice: Environmental Law and Practice § 8.2, at 288-89 (2d ed. 2007).

2010Hallauer v. Spectrum Props., Inc., 143 Wn.2d 126, 134 , 18 P.3d 540 (2001); In re Surface Waters of Deadman Creek Drainage Basin, 103 Wn.2d 686 , 694 P.2d 1071 (1985); 23 Timothy Butlek & Matthew King, Washington Practice: Environmental Law and Practice § 8.2, at 288-89 (2d ed. 2007).

22010–2010
Neubert v. Yakima-Tieton Irrigation District green
wash · 1991
2 sentences

2002RCW 90.03.010; Postema v. Pollution Control Hearings Bd., 142 Wn.2d 68, 79 , 11 P.3d 726 (2000); Neubert v. Yakima-Tieton Irrigation Dist., 117 Wn.2d 232, 240-41 , 814 P.2d 199 (1991).

2002RCW 90.03.010; Postema v. Pollution Control Hearings Bd., 142 Wn.2d 68, 79 , 11 P.3d 726 (2000); Neubert v. Yakima-Tieton Irrigation Dist., 117 Wn.2d 232, 240-41 , 814 P.2d 199 (1991).

22002–2002
Postema v. Pollution Control Hearings Bd. green
wash · 2000
2 sentences

2002RCW 90.03.010; Postema v. Pollution Control Hearings Bd., 142 Wash.2d 68, 79 , 11 P.3d 726 (2000); Neubert v. Yakima-Tieton Irrigation Dist., 117 Wash.2d 232, 240-41 , 814 P.2d 199 (1991).

2002RCW 90.03.010; Postema v. Pollution Control Hearings Bd., 142 Wn.2d 68, 79 , 11 P.3d 726 (2000); Neubert v. Yakima-Tieton Irrigation Dist., 117 Wn.2d 232, 240-41 , 814 P.2d 199 (1991).

22002–2002
Foster v. Department of Ecology green
wash · 2015
1 sentence

2019The prior appropriation doctrine “does not permit any impairment, even a de minimis impairment, of a senior water right.” Foster, 184 Wn.2d at 471 .

12019–2019

Statutes the citing opinions construe

WA § Wash. Rev. Code § 90.03.010 (11) WA § Wash. Rev. Code § 90.44.050 (11) WA § Wash. Rev. Code § 90.54.020 (11) WA § Wash. Rev. Code § 90.03.290 (10) WA § Wash. Rev. Code § 34.05.570 (8) WA § Wash. Rev. Code § 90.22.010 (8) WA § Wash. Rev. Code § 90.03.247 (7) WA § Wash. Rev. Code § 90.44.020 (7) WA § Wash. Rev. Code § 90.54.010 (6) WA § Wash. Rev. Code § 90.54.040 (6) WA § Wash. Rev. Code § 36.70A.020 (5) WA § Wash. Rev. Code § 77.57.020 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CO 53 (1892–2025) CA 27 (1927–2025) NM 26 (1931–2025) WA 15 (1991–2025) NY 14 (1861–2014) OR 13 (1923–2025) AZ 12 (1907–2016) ID 11 (1974–2024) IL 9 (1994–2026) MT 7 (1983–2024) NV 5 (2016–2024) WY 5 (1900–2014) LA 5 (1992–2025) UT 5 (1943–2020) NE 4 (1903–1993) OH 3 (2006–2025) KS 3 (1962–2011) TX 3 (1930–1996) IN 3 (1909–1977) MI 2 (1970–2001) GA 2 (1887–2013) AR 2 (1893–1953) AK 2 (2018–2018) WI 2 (1982–2001) OK 2 (1972–2010) MD 2 (2012–2012) PA 2 (1886–1943)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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