Southwestern Bell Telephone Company, Petitioner v. Public Utility Commission of Texas, Respondents

Summary

The Texas Supreme Court held that judicial review of Public Utility Commission rate orders is limited to the agency record under the substantial‑evidence rule, striking the pre‑emptive trial‑de‑novo language in PURA §69 as void and severable; it further held that the proper rate base is the adjusted value of invested capital under PURA §41(a) and that "invested capital" means original cost less depreciation, affirming the trial court's denial of a temporary injunction and the Commission's rate‑base determination except for the erroneous blanket exclusion of land held for future use, which was not deemed confiscation.