United States v. New Mexico

The federal government (defendant) asserted implied reserved rights to instream water flow in the Gila National Forest for aesthetic, environmental, recreational, fishing, and livestock-watering purposes, relying on the implied-reservation-of-water-rights doctrine. New Mexico (plaintiff) initiated a water-rights adjudication, and the state courts found the Organic Administration Act (OAA) authorized reserved federal water rights only for water-flow conservation and timber supply, while the later Multiple-Use Sustained-Yield Act (MUSY), which expanded national forests' purposes to include recreation and wildlife, did not independently expand those reserved water rights.