In 1970, the USGS began a study to determine why the water level was receding at Devils Hole, concluding that a substantial withdrawal of groundwater would negatively affect the water level, and thus, pupfish habitat. In August 1971, the U. S. Department of Justice filed a complaint on behalf of the Department of the Interior, seeking to stop Spring Meadows from using three wells identified as having the greatest impact on Devils Hole. The basis for the argument was that when Devils Hole became part of a National Monument in 1952, sufficient water was thus reserved "to serve the requirements and purposes of the monument". Later that month, Spring Meadows and the federal government made an agreement that they would cease operation of the three identified wells, and not increase withdrawal at their other wells to compensate. Though the water level briefly rose, it once again entered a decline, exposing more than half the shallow shelf by summer 1972. This caused the government to reactivate the suit in 1972. Now, they wanted Spring Meadows to cease using any wells within of Devils Hole for any non-domestic purpose based on the implied reservation doctrine established in "Winters v. United States" (1908). An injunction in favor of the government was issued in June 1973, which was appealed to the United States Court of Appeals for the Ninth Circuit (upheld in 1974) and the Supreme Court.