Total Environmental Solutions, Inc. v. Mississippi Public Service Commission

Summary

The Supreme Court of Mississippi reviewed the Mississippi Public Service Commission’s order setting water-service rates for Total Environmental Solutions, Inc. The court held that the Commission’s order was not supported by substantial evidence and was contrary to the manifest weight of the evidence because it provided no cogent basis for the rate imposed or for abolishing metered rates. The court reversed the chancery court’s judgment and remanded the matter to the Commission for further findings.

Holdings

1. The Commission's order denying the stipulated water-rate increase was not supported by substantial evidence and was contrary to the manifest weight of the evidence.
2. The Commission must incorporate cogent reasons and findings of fact pertinent to the particular rate inquiry and must set forth the basis on which rates are fixed; an order providing no basis for the imposed rate or abolition of metered rates is legally inadequate.

Questions Presented

1. Whether the Mississippi Public Service Commission's denial of the stipulated water-rate increase was supported by substantial evidence.
2. Whether the Commission's order adequately stated factual findings and reasons supporting the rates it imposed to permit meaningful judicial review.

Disposition

reversed_and_remanded