## Facts

- Hutchins Lake is a spring-fed inland lake in Allegan County, Michigan, with a normal area of about 350 acres and an outlet that may stop flowing in dry conditions.
- About 75 cottages and several farms abutted the lake.
- Defendant Crane owned a 180-acre farm abutting the lake, with roughly one-quarter mile (about 10%) of the lake’s frontage, and used lake water to irrigate his fruit operation during the summer of 1958.
- Plaintiff Hoover owned and operated a resort on the lake; other plaintiffs were cottage and resort owners whose primary uses included swimming and boating.
- The summer of 1958 was abnormally dry, and the lake level fell to the lowest point in recent memory.
- Plaintiffs alleged that Crane’s pumping caused the lake level to drop an additional six to eight inches, creating serious problems for resort guests and other recreational users.
- Crane disputed that his irrigation was the main cause of the lowered lake level, pointing to the unusual drought.
- The circuit court (sitting in equity) found that abnormal weather was a much greater cause of the lake’s reduced level than Crane’s withdrawals, though Crane’s pumping contributed to some degree.
- The circuit court entered a decree recognizing Crane’s right to make a reasonable use of the lake water and permitting him, during each dry period, to pump a limited amount measured as the equivalent of up to one-quarter inch of the lake’s depth (tied to conditions such as when the outlet was not flowing).
- Plaintiffs appealed, arguing that the decree allowed unlawful interference with their riparian and recreational uses.

## Issues

1. Whether a riparian owner’s withdrawal of water from an inland lake for irrigation during an abnormal drought may be a reasonable use even if it lowers the lake level and interferes with other riparian owners’ boating and swimming.
2. Whether the circuit court properly exercised equitable authority by defining “reasonable use” through a quantitative, metered limitation and conditions tied to dry periods.

## Decision

- The Michigan Supreme Court affirmed the circuit court’s decree.
- The Court accepted the circuit court’s factual finding that abnormal weather conditions caused the lake’s low level far more than Crane’s pumping.
- The Court held that irrigation can qualify as a reasonable riparian use, and that other riparians are not entitled to relief for harm that is merely incidental to a neighbor’s reasonable exercise of the common right.
- The Court approved the decree’s approach of allowing irrigation only within specified limits (measured by a meter and expressed as a fraction of lake depth per dry period) as an appropriate judicial method for resolving competing riparian uses.

## Legal Principles

- Riparian owners on an inland lake share correlative rights to use the water; each owner’s use is constrained by the requirement of reasonableness in relation to other riparians.
- Michigan applies a “reasonable use” approach, not a strict rule requiring maintenance of an unchanged, “natural” level for all conditions.
- Reasonableness is determined from all the circumstances, including the purpose of the use (e.g., irrigation), the extent and timing of the withdrawal, the character of the water body, and the nature and degree of interference with other riparian uses.
- Some injury to other riparians does not give rise to a remedy when it results from a reasonable enjoyment of the shared right; the law does not prohibit every measurable interference.
- A court of equity may craft practical, conditional relief—such as metering and numerical limits tied to dry periods—to define and control reasonable use and to reduce conflict among riparian owners.

## Conclusion

Hoover v. Crane upheld a decree that treated irrigation from a spring-fed inland lake as a permissible riparian use when kept within measured limits during drought conditions, affirming that Michigan’s riparian law allows productive uses that may cause some recreational inconvenience so long as, in context, the use remains reasonable.


Hoover v. Crane, 106 N.W.2d 563 (1960)