In Winters v. United States (1908), the Supreme Court held that the right to use waters flowing through or adjacent to the Fort Berthold Indian Reservation was reserved to American Indians by the treaty establishing the reservation. Although this treaty did not mention water rights, the Court ruled that the federal government, when it created the reservation, intended to deal fairly with American Indians by preserving for them the waters without which their lands would have been useless. Later decisions, citing Winters, established that courts can find federal rights to reserve water for particular purposes if (1) the land in question lies within an enclave under exclusive federal jurisdiction, (2) the land has been formally withdrawn from federal public lands—i.e., withdrawn from the stock of federal lands available for private use under federal land use laws-and set aside or reserved, and (3) the circumstances reveal the government intended to reserve water as well as land when establishing the reservation.

    Some American Indian tribes have also established water rights through the courts based on their traditional diversion and use of certain waters prior to the United States' acquisition of sovereignty. For example, the Rio Grande pueblos already existed when the United States acquired sovereignty over New Mexico in 1848. Although they at that time became part of the United States, the pueblo lands never formally constituted a part of federal public lands; in any event, no treaty, statute, or executive order has ever designated or withdrawn the pueblos from public lands as American Indian reservations. This fact, however, has not barred application of the Winters doctrine. What constitutes an American Indian reservation is a question of practice, not of legal definition, and the pueblos have always been treated as reservations by the United States.This pragmatic approach is buttressed by Arizona v. California (1963), wherein the Supreme Court indicated that the manner in which any type of federal reservation is created does not affect the application to it of the Winters doctrine. Therefore, the reserved water rights of Pueblo Indians have priority over other citizens' water rights as of 1848, the year in which pueblos must be considered to have become reservations.

  Historians have identified two dominant currents in the Russian women's movement of the late tsarist period. ''Bourgeois" feminism, so called by its more radical opponents, emphasized ''individualist" feminist goals such as access to education, career opportunities, and legal equality. ''Socialist" feminists, by contrast, emphasized class, rather than gender, as the principal source of women's inequality and oppression, and socialist revolution, not legal reform, as the only road to emancipation and equality.
  However, despite antagonism between bourgeois feminists and socialist feminists, the two movements shared certain underlying beliefs. Both regarded paid labor as the principal means by which women might attain emancipation: participation in the workplace and economic self-sufficiency, they believed, would make women socially useful and therefore deserving of equality with men. Both groups also recognized the enormous difficulties women faced when they combined paid labor with motherhood. In fact, at the First All-Russian Women's Congress in 1908, most participants advocated maternity insurance and paid maternity leave, although the intense hostility between some socialists and bourgeois feminists at the Congress made it difficult for them to recognize these areas of agreement. Finally, socialist feminists and most bourgeois feminists concurred in subordinating women's emancipation to what they considered the more important goal of liberating the entire Russian population from political oppression, economic backwardness, and social injustice.