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Southwest Louisiana Electric Membership Corp. v. Louisiana Public Service Commission

Citations: 441 So. 2d 1201; 1983 La. LEXIS 12339; 1983 WL 821928Docket: No. 83-CA-1199

Court: Supreme Court of Louisiana; November 27, 1983; Louisiana; State Supreme Court

Narrative Opinion Summary

In this case, Southwest Louisiana Electric Membership Corporation (SLEMCO) contested the actions of Central Louisiana Electric Company (CLECO) regarding the extension of electric service to a new facility owned by Martco Partnership. SLEMCO alleged that CLECO's extension violated Louisiana Revised Statutes section 45:123 and a Commission General Order intended to prevent duplicative electric services. The Louisiana Public Service Commission, followed by the Nineteenth Judicial District Court, upheld the right of customers, such as Martco, to choose their utility provider, affirming CLECO's action. The court found SLEMCO's claim unfounded, as the statutory distance requirements under La.R.S. 45:123 were not met, and CLECO's extension did not contribute to wasteful competition. Furthermore, the Commission's authority to allow customer choice was supported by precedent, and its decisions were presumed valid unless proven otherwise. Consequently, the court affirmed the Commission's order, concluding that CLECO's service extension was lawful and aligned with the public interest, resulting in a favorable outcome for CLECO and validating the customer's utility selection.

Legal Issues Addressed

Application of La.R.S. 45:123

Application: The statute did not apply as the distance between CLECO’s meter connection and SLEMCO’s line exceeded statutory limits.

Reasoning: The court found SLEMCO’s claims lacking merit, concluding that the distance between CLECO’s meter connection and SLEMCO’s line exceeded the statutory limits, thus La.R.S. 45:123 was not applicable.

Commission's Decision Presumed Valid

Application: The court emphasized that Commission decisions are presumed valid and affirmed them unless shown to be arbitrary or unsupported by evidence.

Reasoning: The court affirmed the Commission's order, emphasizing that such decisions are presumed valid and should only be overturned if shown to be arbitrary or unsupported by evidence.

Customer Choice in Utility Service

Application: The court affirmed the right of customers to choose their electric utility, even when multiple utilities can serve the same area.

Reasoning: The Louisiana Public Service Commission ruled that customers have the right to choose their utility, which the Nineteenth Judicial District Court affirmed.

Prohibition on Duplicate Electric Service

Application: The court determined CLECO's service extension did not violate the General Order aimed at preventing wasteful duplication of facilities.

Reasoning: The court determined that CLECO's service extension did not violate the General Order regarding duplicate electric service, which aims to prevent wasteful practices to keep rates reasonable.