Merchants Fast Motor Lines, Inc. v. Railroad Commission of Texas

Summary

The Texas Supreme Court held that the Administrative Procedure Act does not apply to an agency order issued before the Act’s effective date, so the 1975 Railroad Commission order must be reviewed under the pre‑APA Motor Carriers Act and affirmed the trial court’s judgment voiding the rate provisions. The Court also held that the APA’s remand provision was inapplicable, reversing the Court of Civil Appeals’ remand. Justice Chadick dissented, arguing that the APA should govern and the case should be remanded for a full hearing.