One of the all-time great stories of American environmental law, the Mono Lake saga recounts the protracted conflict over scarce water resources between the City of Los Angeles and advocates for the Mono Basin, Yosemite’s eastern watershed, some four hundred miles to the north. In 1983, in National Audubon Society v. Superior Court, the California Supreme Court famously addressed the conflict by centering the State’s obligations under the common law public trust doctrine, which sets forth public rights and obligations in certain natural resource commons, especially navigable waterways.

The Mono Lake conflict followed a century of California’s efforts to cope with limited water resources in the face of compelling but conflicting demands, culminating in a historic legal decision that continues to influence environmental dilemmas worldwide. Audubon Society plumbed an inexorable conflict between the public commons approach that underlies public trust regulation of waterways and the privatization premise of the prior appropriations doctrine of western water allocation, which assigns rights to withdraw from a watercourse on a first-in-time basis. The High Court used the case to frame the public trust doctrine as a quasi-constitutional foundation of state law that creates sovereign obligations of stewardship and corresponding public environmental rights in trust resources. The case proved an inflection point in the development of the doctrine, revealing its evolution from a justification for sovereign power over trust resources to a mandate for the protection of their environmental values.

The Mono Lake case will turn fifty in the coming decade. After all these years, the Mono Lake story still prompts reflection about the way the public trust doctrine navigates complex conflicts between public and private rights in natural resource commons, from ancient protections for waterways to contested modern claims for atmospheric resources. Nevertheless, while the decision itself is well represented in the legal literature, the full story of the case has not received the attention it deserves. This Article offers fresh perspective on the least recounted but critical parts of the story — not only the significance of the legal innovations in the decision, but also what happened beforehand to lay the foundations for the landmark ruling, and then what happened afterward to bridge the court’s holding to the ultimate outcome for Mono Lake.

Part I outlines the prologue to the litigation, recounting the strategic mobilization of urban and rural communities of interest to protect the failing lake. It tells the story of how a loosely organized coalition of locals, scientists, birdwatchers, and scholars forged a rare rural-urban partnership that laid the foundations for change. Part II reviews the case itself, analyzing the legal arguments and the significant doctrinal developments in the final decision, which affirmed its application to environmental values, extended its reach over space and time, and ensured its durability against countervailing statutory claims. Part III explores the aftermath and implementation of the decision, including the protection of surrounding public lands, a series of buttressing litigation by CalTrout and other plaintiffs, the Water Board’s implementation of these judicial directives in the famous “Decision 1631,” and Los Angeles’ resulting embrace of conservation. Part IV concludes with updates on the state of affairs in both the Mono Basin and the Owens River Valley, where bitter contests over the competing uses of scarce water resources remain as challenging as ever, and as they likely will remain.