42 BULLETIN 1177, U. S. DEPARTMENT OF AGRICULTTJRF 
board of county supervisors, which petition, if sufficient in form, 
must be granted. Thereupon the supervisors were required to call 
an election at which all electors in the area described were allowed 
to vote for or against the organization of the proposed district, and 
for district officers, an affirmative vote of two-thirds of those voting 
being necessary to authorize formation. If declared organized, the 
board of directors of the district was given power to acquire, by pur- 
chase or condemnation, the necessary property, water rights,, and 
irrigation works; to call elections on the question of issuing bonds, 
at which a majority of the votes cast was sufficient to authorize a 
bond issue; to issue and sell bonds in the amount authorized and to 
use the proceeds for the purchase or construction of irrigation works; 
to levy annual assessments to meet the interest and principal of out- 
standing bonds, and to call elections on the question of special assess- 
ments; and generally to manage and conduct the affairs of the district 
to the end that a system of irrigation works should be constructed 
or purchased, water delivered, and the district obligations paid as due. 
The essence of the irrigation district law, then, was the permission 
given to a part of the residents of a given area to incur indebtedness 
for which all the lands in such area were held liable. Fifty or a 
majority of the landowners might propose the organization of a dis- 
trict; but once organized, a majority of the electors voting at any 
bond election, whether landowners or not, might bond the district 
in any amount they pleased. The advantage thus given to groups 
of small landowners is obvious, and just as apparent is the certainty of 
resulting opposition of unwilling owners of large tracts to a scheme 
of things which had not yet been tried in the courts and which was 
soon seen to involve constitutional questions. If those who wished 
irrigation could have built systems to cover only their own lands, 
much of the early litigation would have been avoided. But the 
situation in San Joaquin Valley which gave birth to the Wright Act 
resulted from the decreasing yields of grain due to farming the land 
year after year to this one crop and the consequent unprofitableness 
of dry-grain farming on small areas while large acreages could still 
be made to yield a profit. At the same time the cost of bringing 
water to the small areas alone might be prohibitive, yet be entirely 
within reason if spread over additional adjacent areas. It, was to 
remedy such conditions, and to enable the needed additional areas 
to be brought within districts, supplied with water, and taxed to 
pay their proportion of the cost of irrigation, that the irrigation 
district law was placed on the statute books of California. 
As above stated, much litigation arose over the formation and 
bond issues of the early districts. The objecting landowners claimed 
that the sale of their lands for district taxes constituted an infringe- 
ment of the Federal Constitution in that it involved taking property 
without due process of law. The California State courts held 
repeatedly that neither the State nor the Federal Constitution was 
violated, and although in the first Federal case to pass on the question 
the circuit court held the Wright Act unconstitutional, the United 
States Supreme Court in 1896 reversed the decision and established 
for all time the constitutionality of the irrigation district law. 8 The 
broad ground was taken in this decision that in a State like California, 
sFullbrook Irrigation District v. Bradley, 164 U. S. 112. 
