Escondido Mutual Water Co. v. La Jolla Band of Mission Indians

Escondido (defendant... plaintiff on appeal) sought a FERC hydropower license for a project on or near Southern California tribal reservations; FERC issued the license without including conditions the Interior Secretary had imposed to protect tribal interests, reasoning § 4(e) didn't require unmodified acceptance of the secretary's conditions and that its required no-interference-or-inconsistency finding only applied to reservation land physically occupied by project facilities. The La Jolla Band and other tribes (plaintiffs... defendants on appeal) petitioned for review; the court of appeals reversed FERC as to the secretary's conditions and held that "reservations" for purposes of the no-interference finding included tribal water rights beyond the physical project footprint. The Supreme Court granted certiorari to resolve the Act's proper scope.