Arkansas Louisiana Gas Co. v. Department of Public Utilities

1938-04-25
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Headline: Court upholds Arkansas order requiring a gas company to file contracts and rate information, finding the reporting requirement does not unreasonably burden interstate natural gas deliveries and may be enforced.

Holding: The Court held that Arkansas may require the company to file contracts and rate information because the reporting order does not unconstitutionally burden or unduly interfere with interstate gas commerce.

Real World Impact:
  • Requires gas companies to file contracts and rate information with Arkansas regulators.
  • Allows state regulators to obtain comprehensive operational reports without halting interstate deliveries.
Topics: interstate commerce, utility regulation, natural gas, state reporting requirements

Summary

Background

A Delaware gas company buys and produces natural gas in Texas and Louisiana and delivers large volumes into Arkansas to industries and local utility distributors under contracts made in Shreveport, Louisiana. The company also runs a separate local distribution operation in many Arkansas towns. The Arkansas Department of Public Utilities issued a general order requiring utilities to file schedules and related information. The company filed local schedules but refused to provide copies of contracts and delivery details for its pipeline customers and was ordered to comply.

Reasoning

The central question was whether the State could force the company to file the requested information without violating federal protections for interstate commerce. The company argued those sales and deliveries were interstate commerce and thus beyond state control. The Court explained that simply being part of interstate commerce did not justify refusing to supply information. Requiring comprehensive reports about both local and interstate operations would not materially burden or unduly interfere with the free flow of commerce, so the State’s reporting order was constitutional. The Court affirmed the state court’s judgment and left open the right to challenge any future, more burdensome regulation.

Real world impact

Regulators in Arkansas can require the company to produce contracts and rate information now, giving officials a fuller picture of local and pipeline operations. The ruling does not decide whether the State may later set or enforce rates; if the Department tries to impose unreasonable restraints on interstate business, the company may contest those actions in court. The decision resolves the reporting dispute in favor of the State while reserving challenges to any future overreaching measures.

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