Montana-Dakota Utils., Co. v. Wyo. Pub. Serv. Comm’n

Montana-Dakota Utilities Company (MDU) was ordered by the Wyoming Public Service Commission to make refunds of the amounts MDU had overcharged its customers because of improper calculations and adjustments to its commodity balancing account. MDU filed a petition for review, challenging the legal authority of the Commission to order refunds. The district court affirmed the Commission’s decision. The Supreme Court affirmed, holding (1) the rule against retroactive ratemaking did not preclude the Commission from ordering the refund; (2) the Commission’s refund order did not violate the file rate doctrine; (3) the Commission was not subject to a statute of limitations in this case; (4) MDU failed to show that the Commission was equitably estopped from ordering a refund; and (5) the Commission’s action was not arbitrary, capricious, an abuse of discretion, or unlawful. View "Montana-Dakota Utils., Co. v. Wyo. Pub. Serv. Comm’n" on Justia Law