in Mono Basin, and sought declaratory and injunctive relief. The Public Trust Case was originally argued as: National Audubon Society v. Los Angeles. Superior Court of Alpine County No. 6429. The case was transferred to Alpine Superior Court; DWP filed a cross-complaint seeking adjudication of Basin water rights to all appropriators, naming 117 cross-defendants, including the plaintiffs, the State, United States Forest Service, U.S Bureau of Land Management, and other private water users. DWP also sought a Congressional declaration stating they consented to the impairment of navigable waters of Mono Lake. Finally, DWP asserted that any nuisance at Mono Lake was attributable to the newly exposed lakebed and sought a declaration that conditions resulted from a valid exercise of the police power by the State of California. Simultaneously, Audubon sought permission to include a cause of action based on the federal common law of nuisance, asserting that Mono Lake is an "interstate or navigable" water in which there is an overriding federal interest, and DWP's diversions were causing water and air pollution. Due to the inclusion of federal agencies, the suit was transferred to Federal District Court, where they decided abstention was appropriate and remanded. Accordingly, Audubon was instructed to file an action in state court to resolve two key issues: 1.) The interrelationship between the California water rights system and the public trust doctrine: Is the public trust doctrine in this context subsumed in the California water rights system, or does it function independently of that system? Could the plaintiffs challenge the DWP's permits by asserting the public trust doctrine limits their permits and licenses, or argue that the water diversions are not "reasonable or beneficial," as required under the California water rights system? And 2.) Whether exhaustion of administrative remedies was pursued or is applicable in this context. This case eventually reached the Supreme Court of California, carrying this title: National Audubon Society v. Superior Court. 33 Cal. 3d 419 (1983). Case At the beginning of the 20th century, the city of Los Angeles, which lies south of Mono Lake, began to undergo huge growth. As a result of this growth, the city needed additional sources of water. Around 1905, former Los Angeles Mayor, Fred Eaton, and his colleague William Mulholland, began to buy land in the Sierra Nevada region to secure water supply. The Owens River was utilized as a water source until 1919, and when the