Center for Biological Diversity, Inc. v. Public Utilities Commission

Summary

The California Supreme Court modified its August 7, 2025 opinion concerning the level of judicial deference owed to the California Public Utilities Commission’s interpretation of the Public Utilities Code. The court held that the highly deferential Greyhound standard does not govern review of most Commission decisions under current Public Utilities Code sections 1757 and 1757.1, and remanded for review under the applicable statutory standard. The modification order corrected citations and revised language without affecting the judgment.

Holdings

1. For Commission decisions other than those pertaining solely to water corporations, the amended versions of Public Utilities Code sections 1757 and 1757.1 do not permit the uniquely deferential Greyhound approach to govern review of the Commission's interpretation of the Public Utilities Code.
2. Courts must independently judge the text and legal meaning of the statute, while considering and respecting the Commission's interpretation according to the contextual factors identified in Yamaha.
3. The Supreme Court did not decide whether the tariff is consistent with section 2827.1; the Court of Appeal must address that question in the first instance under the proper standard.

Questions Presented

1. Whether the highly deferential standard stated in Greyhound Lines, Inc. v. Public Utilities Commission continues to govern judicial review of Public Utilities Commission decisions under the amended versions of Public Utilities Code sections 1757 and 1757.1.
2. Whether the Court of Appeal erred by reviewing the Commission's interpretation of Public Utilities Code section 2827.1 under the Greyhound standard rather than independently evaluating the statutory issue under the Yamaha framework.
3. Whether the challenged tariff is consistent with Public Utilities Code section 2827.1 under the proper standard of review.

Disposition

reversed_and_remanded