## Facts

- Pinto Lake was a natural body of water in Santa Cruz County, California, bordered by land owned by the McKinlay family with riparian rights in the lake’s waters.
- Before S. J. Duckworth acquired any interest, the McKinlays executed a deed conveying their riparian water rights in Pinto Lake to Watsonville Water & Light Co.
- The company diverted water from the lake and supplied nonriparian users in the City of Watsonville and nearby areas.
- Duckworth later acquired an interest in adjoining land through marriage to a McKinlay family member and began diverting water from Pinto Lake to irrigate his land.
- The trial court found the company also owned a riparian strip bordering the lake, with about 5.5 cultivable acres requiring no more than approximately 10 miner’s inches of water for irrigation.

## Issues

1. Whether the McKinlays’ deed validly conveyed riparian rights in Pinto Lake to Watsonville Water & Light Co. so as to bind later successors claiming through the McKinlays.
2. Whether Duckworth, as a later claimant deriving his interest through the McKinlay family, could assert water rights superior to or inconsistent with the company’s earlier deed-based and diversion-based rights.
3. What quantity of water the company, as riparian owner of limited cultivable acreage, was entitled to use under the reasonable-use limits of riparian doctrine.

## Decision

- The California Supreme Court affirmed the judgment recognizing the company’s prior position in the Pinto Lake water rights and rejecting Duckworth’s broader claims.
- The Court held the McKinlays’ deed effectively conveyed their riparian rights to Watsonville Water & Light Co., giving the company a superior claim as against later successors.
- The Court held Duckworth could not assert water rights that enlarged, revived, or conflicted with rights the McKinlays had already conveyed away.
- The Court sustained the limitation of the company’s riparian use to the amount reasonably needed for its riparian land, upholding the finding that no more than about 10 miner’s inches were required to irrigate approximately 5.5 cultivable acres.

## Legal Principles

- A valid conveyance by deed of riparian water rights binds successors who later take through the same grantor; a successor cannot obtain greater rights than the grantor retained.
- Priority governs competing water claims: earlier deed-based rights and earlier lawful diversions prevail over later uses asserted by a subsequent claimant.
- Riparian rights are limited by reasonable and beneficial use on the riparian parcel; riparian status does not justify diversion beyond the needs of the riparian land.

## Conclusion

The court enforced the prior deed transferring riparian rights to the water company and held that a later successor claiming through the original riparian owners could not divert Pinto Lake water in a manner inconsistent with the earlier conveyance; the company’s riparian entitlement was confined to the reasonable irrigation needs of its limited riparian acreage.


Duckworth v. Watsonville Water & Light Co., 158 Cal. 206, 110 P. 927 (Cal. 1910)