West Ohio Gas Co. v. Public Utilities Commission’s Empirical Analysis
294 U.S. 63 · 1935
Citation profile
90 federal appellate · 15 district · 198 state decisions
How this case has been cited
Cited by 406 later decisions (47 by the Supreme Court) — most recently July 2006 · most notably Central Hudson Gas Electric Corporation v. Public Service Commission of New York (1980), Joint Anti-Fascist Refugee Committee v. McGrath (1951)
90 federal appellate · 15 district · 198 state decisions — followed in 36 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Kornhauser v. United States · State of Missouri Southwestern Bell Telephone Co v. Public Service Commission of Missouri · Federal Radio Commission v. Nelson Bros. Bond & Mortgage Co. · Los Angeles Gas Electric Corporation v. Railroad Commission of California · Dayton Power & Light Co. v. Public Utilities Commission
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 406 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a showing of inefficiency or improvidence.”
7 later decisions quote this exact passage · from the majority““We do not now decide that there would be a denial of due process through the spread of distributing costs over the total area of service, if the new method of allocation had been adopted after timely notice to the company and then consistently applied. This court does not sit as a board of revision with power to review the action of administrative agencies upon grounds unrelated to the maintenance of constitutional immunities. Los Angeles Gas & Electric Corp. v. Railroad Commission of California, 289 U. S. 287 . Our inquiry in rate cases coming here from the state courts is whether the action of the state officials in the totality of its consequences is consistent with the enjoyment by the regulated utility of a revenue something higher than the line of confiscation. If this level is attained, and attained with suitable opportunity through evidence and argument (Southern Ry. Co. v. Virginia, 290 U. S. 190 ) to challenge the result, there is no denial of due process, though the proceeding is shot through with irregularity or error.””
4 later decisions quote this exact passage · from the majority“A public utility will not be permitted to include negligent or wasteful losses among its operating charges.”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.