Because of these plural systems of water allocation, disputes soon ensued; these differences were resolved by the state courts. In 1872, the Legislature adopted a procedure in the Civil Code to provide a method for those claiming an appropriative water right to record their claims with the county recorder of each county. In 1886, the courts addressed competing claims between riparians and appropriators in the case of ""Lux v. Haggin."" However, within 25 years, excessive claims to water rights threatened to affect economic development in the state. In response, the governor formed a Water Commission to make recommendations regarding California's water law. In 1913, Californian voters adopted by referendum the Water Commission Act, which created the state Water Commission and set forth an administrative procedure for acquiring an appropriative right.