Federal Power Commission v. Southern California Edison Co.

Southern California Edison Company (Edison) (defendant) was an electric utility company operating in southern California. Edison sold electricity only to Californian customers. Some of the electricity sold by Edison originated in Nevada and Arizona. The Hoover Dam in Nevada, the Davis Dam in Arizona, and the Parker Dam in California were all interconnected by a transmission line used by Edison to draw electricity. The City of Colton, California (plaintiff) purchased all of its electricity requirements from Edison. Colton used some of the electricity itself and resold the rest to customers within the city. In other words, Colton purchased wholesale electricity from Edison and distributed it to retail customers. The Public Utilities Commission of California (defendant) had exercised jurisdiction over the sales between Edison and Colton for years. However, in 1958, the Federal Power Commission (plaintiff) asserted jurisdiction under § 201(b) of the Federal Power Act over such sales because it found that some of the electricity sold to Colton was generated outside of California. The court of appeals held that the Federal Power Commission did not have jurisdiction because state regulation was permissible under the Commerce Clause of the United States Constitution. The court of appeals reasoned that state regulation of the sale between Edison and Colton would not harm the interests of other states. The United States Supreme Court granted certiorari.