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Construction of major dam projects in the Western States requires a re-examination of Indian water rights. Roughly analogous to the nineteenth century problem of Indian land rights, the twentieth century issue of Indian water rights has shifted from water ownership to its best use. Conflicts exist between the western water law of prior appropriation and the Indian rights to the water. The United States Supreme Court addressed the issue in Winters v. United States by holding that the Indian rights controlled over state law. However, the standard for measuring the quantity of water reserved to the Indians was not determined, subsequently causing much conflict. Although the Winters doctrine grants rights to the American...