SolarCity Corp. v. Salt River Project Agricultural Improvement and Power District
United States District Court for the District of Arizona
2015 WL 6503439 (2015)
- Written by Abby Roughton, JD
Facts
Power-and-water utility Salt River Project (SRP) provided electricity to customers in Phoenix, Arizona. SRP consisted of Salt River Project Agricultural Improvement and Power District (the district) (defendant) and Salt River Valley Water Users’ Association (the association) (defendant). SolarCity Corporation (plaintiff) sold and leased solar-energy systems to customers in Phoenix. The systems allowed users to generate their own electricity, reducing the amount of electricity users had to purchase from utilities. SRP had historically provided incentives for customers who installed solar-energy systems. However, SRP eliminated those incentives in 2013, allegedly after realizing that solar-energy systems were a competitive threat. In 2015, the district approved Standard Electric Price Plans (SEPPs) that imposed a 65-percent rate increase on customers who purchased some electricity from SRP but also generated their own electricity. SolarCity sued the district and the association, asserting antitrust violations and seeking damages. SolarCity defined the relevant market as the market for the provision of electricity to residential and commercial customers in SRP’s service area through the sale of power or the sale or lease of solar-energy systems. SolarCity alleged that the district had used its monopoly power in that market to impose the SEPPs and exclude SolarCity from the market, even though the market had previously supported solar-energy competition. The court dismissed SolarCity’s claims against the association, finding that the association was not involved in approving the SEPPs. The district also moved to dismiss, asserting that (1) Solar City had not properly alleged a relevant market, (2) SolarCity had not alleged an antitrust injury, and (3) the district was protected from damages liability by the Local Government Antitrust Act (LGAA) because the district was a special-function governmental unit established under Arizona law.
Rule of Law
Issue
Holding and Reasoning (Rayes, J.)
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