Zurcher v. Stanford Daily case brief

Zurcher v. Stanford Daily case brief summary
463 U.S. 547 (1978)

CASE SYNOPSIS

The Court of Appeals for the Ninth Circuit decided separate appeals in which either the United States as trustee or certain Indian Tribes on their own behalf, or both, asserted the right to have Indian water rights adjudicated in federal court. In each case, the court of appeals reversed the district court, holding that the state court did not have jurisdiction over Indian water rights. The court granted certiorari and consolidated the cases.

CASE FACTS
In each of the underlying cases, either the United States as trustee or certain Indian Tribes on their own behalf, or both, asserted the right to have certain Indian water rights in Arizona or Montana adjudicated in federal court.

DISCUSSION

• The court found that any limitations that statehood Enabling Acts or other federal legislation may have originally placed on state-court jurisdiction over Indian water rights were removed by the McCarran Amendment, 43 U.S.C.S. § 666, which allowed state courts jurisdiction to adjudicate Indian water rights, including suits brought by Indian tribes and raising only Indian claims. 
• The court, assuming that the state adjudications were adequate to quantify the rights at issue in the federal suits, and taking into account the McCarran Amendment policies, the expertise and administrative machinery available to the state courts, the infancy of the federal suits, the general judicial bias against piecemeal litigation, and the convenience to the parties, concluded that the appellate court had erred in reversing the district court's decision to defer to the state proceedings.

CONCLUSION
The judgment in each of the cases was reversed, and the cases were remanded for further proceedings.


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