Waterford Dist. v. County of Stanislaus

In Waterford Dist. v. County of Stanislaus (1951) 102 Cal.App.2d 839, the court acknowledged the historical differences between the appropriative rights before it and the rights, originally riparian, at issue in CCSF. However, after reviewing the above treatise and other cases discussing the policy of the amendment, the court reached the same result as in CCSF: "Bearing in mind the purposes of the amendment and what we believe to be the common concept of the nature of appropriative water rights, we conclude that they constitute land, as that term is used in the Constitution." (Waterford, supra, 102 Cal.App.2d at p. 847.)