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0219 . . The substantial exception from federal deference to state water laws came with the Supreme Court's development of the reservation doctrine. The real beginning of the doctrine came in the case of Winters v. United States 19/, in which the Supreme Court held that when Congress created an Indian reservation, an unspecified quantity of water, without which the land would be valueless, had been impliedly set aside for the Indian's use and that this reserved right was superior to the rights of subsequent appropriators who had obtained water rights under the applicable state laws, even though the Indians had not made a diversion for beneficial use. The winters Doctrine, as it became known and accepted, was universally thought of as a special rule of Indian law. ~/ However, in the landmark case of Arizona v, California 21/ in 1963, the Court agreed with the Master's conclusion that the principle underlying the reservation of water rights for Indians applies equally to other federal estab- lishments. As a result, the Court upheld reserved rights not only for Indian reservations, but for national forests, national recreation areas, and wildlife refuges. 22/ Concurrent with the development of the reservation doctrine, the Supreme Court was narrowly construing the scope of the state role under the reclamation laws. Since 1902 when the ReclamatioT! Act was enacted, the Supreme Court, prior to its most recent decision, had decided three cases which actually presented questions of interpretation of Section 8 of the Act: Ivanhoe Irrigation District v. McCracken, 23/ City of Fresno v. California, 24/ and Arizona v. california. 25/ Although none of the cases was clearly dispositive of the question of the scope of Section 8, proponents of national power urged that Congress intended federal administration according to federal policies, and 1:.2./ 207 U.S. 564 (1908) . ~/ F. Trelease, Federal-State Relations in Water Law 105 (1971) . ?l./ 373 U. S. 546 (1963) . ~/ Id. ~/ 357 U.S. 275 (1958) . ~/ 372 U.S. 627 (1963) . e./ 373 U.S. 546 (1963) . -5-