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Ohio Bell Telephone Co. v. Public Utilities Commission

301 U.S. 292 (1937)

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Ohio Bell Telephone Co. v. Public Utilities Commission

United States Supreme Court

301 U.S. 292 (1937)

Facts

The Public Utilities Commission (PUC) (defendant) opened a proceeding to set the rates of Ohio Bell Telephone Company (Ohio Bell) (plaintiff). After holding administrative hearings in the proceeding, the PUC had sufficient evidence to ascertain the value of Ohio Bell’s property as of 1925. The PUC set a rate for 1925 based on this evidence. The PUC then set rates for the years 1926 to 1933 by taking official notice of price trends based on property taxes, construction price indexes, and court findings with respect to an Ohio Bell affiliate. The PUC did not include these price trends or their bases in the record. The rates the PUC set for 1926 to 1933 resulted in significant refunds due to Ohio Bell’s customers. Ohio Bell filed a suit to challenge the PUC’s order. Ohio Bell claimed that by not affording it the opportunity to respond to the PUC’s use of the price trends, the PUC violated its procedural due process rights. The matter was appealed to the Supreme Court of Ohio, which affirmed the order. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Cardozo, J.)

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