Constitution of the State of California 1879 Art. I, § 24

The state board of land commissioners shall have the right to lease state or school lands for grazing, agricultural, or other purposes, as may be otherwise provided by law, and to issue geothermal resource leases covering lands leased for grazing, agricultural, or other purposes, provided however, that the lessee under a geothermal resource lease issued under the provisions of this chapter shall have paramount right to the use of so much of the surface of the land as shall be necessary for the purposes of his lease and shall have the right to ingress and egress at all times during the term of such lease.