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Railroad Commission of Texas, Kent Hance, James Nugent, and John Sharp, Its Commissioners, Aggregate Haulers, Inc., Shar Trucking, Inc., Tarmac Transportation, Inc., and Transit Control Services, Inc., D/B/A T. C. S. v. Robert Delgado Construction Company
Citation: Not availableDocket: 03-91-00367-CV
Court: Court of Appeals of Texas; September 23, 1992; Texas; State Appellate Court
Original Court Document: View Document
The Court of Appeals for the Third District of Texas reversed the district court's judgment that vacated the Railroad Commission of Texas's final order denying Robert Delgado Construction Company’s application for a special use motor carrier certificate. The district court had determined that opposing carriers (protestants) did not meet their burden of proof under section 4(e) of the Motor Carrier Act, leading to its remand for reconsideration. However, the Court found that the district court incorrectly applied a "burden of proof" standard instead of the appropriate "substantial evidence" test as outlined in the Administrative Procedure and Texas Register Act (APTRA). The substantial evidence test requires an evaluation of whether the Commission's findings and conclusions are supported by reasonable evidence in the record as a whole. The Court referenced prior cases to clarify this standard, emphasizing that the agency's decision must be justified by evidence that reasonable minds could accept as sufficient. The reviewing court is restricted from substituting its judgment for that of the Commission and must rely solely on the agency's record when assessing substantial evidence for an order. Even if evidence may lean against the Commission's decision, it can still be considered substantial support for that decision. The burden lies with the party challenging the order to show a lack of substantial evidence. The Commission's final orders are presumed valid, and if evidence supports both affirmative and negative findings, the agency's order must be upheld. Any evidentiary conflicts are resolved in favor of the agency's determination. In the administrative hearing, Delgado provided evidence supporting its application under section 4(e) of the Motor Carrier Act, while opponents argued against it based on existing carriers providing 'reasonably adequate service' as per multiple sections of the Act. The Commission evaluated the evidence and made specific findings of fact and conclusions of law. Delgado did not challenge these findings during its rehearing motion or in the original district court petition, resulting in a waiver of any objections. The Commission's unchallenged findings allowed it to reasonably conclude that 'reasonably adequate service' was present, justifying the application's denial. The district court erroneously substituted its judgment regarding the evidence's weight for that of the Commission. Substantial evidence supported the Commission's conclusion of 'reasonably adequate service,' leading to the reversal of the district court's judgment and the affirmation of the Commission's order. The judgment was reversed and rendered, with the second point of error not addressed.