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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 03-14-00735-CV
Regular Panel Decision
Apr 30, 2015

Entergy Texas, Inc.// Office of Public Utility Counsel and Public Utility Commission of Texas v. Public Utility Commission of Texas and Texas Industrial Energy Consumers// Office of Public Utility Counsel and Entergy Texas, Inc.

The Commission’s Order should be affirmed. The Commission reasonably interpreted its prior rate-case order, the Black-box Order, to authorize Entergy to book and amortize a regulatory asset for unrecovered Hurricane Rita reconstruction costs. The Black-box Order was ambiguous concerning the Rita Asset. That order was based on a “black box” settlement—one where only the amount of rates to be collected was set forth, not all of the individual components of a rate case. Because the Black-box Order did not explicitly state whether booking and amortizing the regulatory asset had been authorized, it was ambiguous. Courts defer to an agency’s interpretation of its prior, ambiguous order, and the evidence in the record supports the Commission’s decision. Substantial evidence supports the Commission’s decision that $13 million should be added to Entergy’s storm reserve based on the expenses Entergy incurred to repair equipment after a severe ice storm in 1997. A prior Commission decision that faulted Entergy for poor service quality did not amount to a finding that Entergy could not include the repair costs in the insurance reserve amount. Substantial evidence supports the Commission’s decision that Entergy failed to meet its burden to prove that predicted purchased-power capacity costs were known-and-measurable changes to the test-year data. The record supports the Commission’s decision that Entergy did not meet its burden of proving that requested changes were known and measurable. For example, Entergy based its arguments about purchasing capacity on the assumption that it would always purchase the maximum amount under new contracts. Entergy claimed that it would have more customers in the future. Not only is that speculative, but the utility failed to account for how additional customers would otherwise affect its recovery through rates. And Entergy’s arguments about transmission charges are controlled by numerous unknown variables used in a complex formula. The Commission’s test-year rule is created to avoid just such unknowns. Moreover, most of Entergy’s request for post-test-year changes to transmission costs were based on an agreement that was still waiting for approval from the Federal Energy Regulatory Commission. That is patently not a “known” change. Because substantial evidence supports the Commission’s decisions, the Order should be affirmed.

Utility RegulationRate CasePublic Utility CommissionAppellate BriefHurricane Rita CostsRegulatory AssetStorm Damage ReservePurchased Power CapacityTransmission EqualizationAdministrative Law
References
24
Case No. 09-17-00409-CV
Regular Panel Decision
Aug 16, 2018

ICP, LLC v. Albert C. Busse and Texas Workforce Commission

ICP, LLC appealed a trial court's judgment affirming the Texas Workforce Commission's (TWC) administrative decision requiring ICP to pay contractual severance benefits to Albert C. Busse, totaling $51,000. Busse, terminated by ICP after three years, had claimed severance pay based on an employment offer stipulating six months' salary if terminated after the second year. After an initial reversal by the Wage Claim Appeal Tribunal, the TWC's Commission Appeals upheld Busse's claim, finding the employment agreement valid and the severance tied to his length of service. The Court of Appeals reviewed the trial court's judgment de novo, applying the substantial evidence rule, and ultimately affirmed the trial court's judgment, concluding that substantial evidence supported the TWC's decision.

Severance PayWage ClaimEmployment ContractTexas Payday LawTexas Workforce Commission (TWC)Administrative DecisionJudicial ReviewSubstantial EvidenceAppealContract Interpretation
References
12
Case No. 03-97-00103-CV
Regular Panel Decision
Mar 12, 1998

Continental Casualty Insurance Company v. Functional Restoration Associates Texas Workers' Compensation Commission And Productive Rehabilitation Institute of Dallas for Ergonomics

Continental Casualty Insurance Company (Continental) appealed a trial court's dismissal of its lawsuit against Functional Restoration Associates (FRA), Productive Rehabilitation Institute of Dallas for Ergonomics (PRIDE), and the Texas Workers' Compensation Commission (Commission). Continental sought judicial review of a Commission decision holding it liable for medical costs for an injured employee, James Hood. The trial court had dismissed the suit, citing a lack of statutory jurisdiction for judicial review of Division of Medical Review (DMR) decisions. On appeal, Continental asserted both statutory and inherent bases for jurisdiction. The appellate court found no explicit or necessarily implied statutory right to judicial review of DMR decisions. However, it concluded that Continental possessed an inherent right to judicial review because the Commission's decision directly affected Continental's vested property interest in the money it was ordered to pay. Consequently, the appellate court reversed the trial court's judgment of dismissal and remanded the cause for further proceedings, including a review of whether the Commission's decision was arbitrary and capricious or unsupported by substantial evidence.

Workers' CompensationJudicial ReviewAdministrative LawDue ProcessVested Property RightsMedical Benefits DisputeAppellate JurisdictionTexas LawStatutory InterpretationSubstantial Evidence
References
28
Case No. MISSING
Regular Panel Decision

Texas Employment Commission v. Briones

Maria M. Briones and 213 other claimants appealed an administrative determination by the Texas Employment Commission, which had awarded them reduced unemployment benefits due to holiday pay received from their employer, Friedrich Refrigerators, Inc. The trial court initially set aside the Commission's decision, granting full benefits to the claimants. However, the appellate court reversed the trial court's judgment, affirming the Texas Employment Commission's original decision. The central issue was whether holiday pay constituted "wages" under the Texas Unemployment Compensation Act and if it should be attributed to the week the holiday occurred, thereby leading to partial unemployment benefits. The court concluded that holiday pay was indeed wages and attributable to the holiday week, classifying claimants as partially unemployed.

Unemployment benefitsHoliday payWagesStatutory interpretationAdministrative appealPartial unemploymentCollective bargaining agreementEmployer shutdownLabor lawAppellate review
References
8
Case No. 03-03-00428-CV
Regular Panel Decision
Sep 23, 2005

Cities of Corpus Christi, Appellants//AEP Texas Central Company Public Utility Commission of Texas And Constellation New Energy, Inc. v. Public Utility Commission of Texas and AEP Texas Central Company, Appellees//Public Utility Commission of Texas Cities of Corpus Christi Office of Public Utility Counsel And Constellation NewEnergy, Inc.

This dissenting opinion addresses an appeal regarding the Public Utility Commission's authority to order AEP Texas Central Company to refund excess earnings from accelerated recovery of stranded costs. The dissenting Justice agrees with the majority on affirming the Commission's decisions concerning member account balances and demand charges. However, the dissent strongly contends that the Commission possessed the authority to mandate these refunds prior to 2004, arguing the statutory scheme was ambiguous and the Commission's action was a reasonable interpretation consistent with its duties to promote fair competition and prevent overrecovery. The dissent highlights that the majority's interpretation may lead to absurd results by limiting the Commission's ability to correct overrecovery while allowing it to address underrecovery.

Electricity DeregulationStranded CostsUtility RegulationPublic Utility CommissionRegulatory AuthorityExcess EarningsRefundsCompetitive MarketTexas Utility CodeAdministrative Law
References
12
Case No. 03-02-00246-CV
Regular Panel Decision
Aug 26, 2004

Reliant Energy, Incorporated Office of Public Utility Counsel And Gulf Coast Coalition of Cities/Magic Valley Electric Cooperative, Inc. Medina Electric Cooperative, Inc. Rayburn Country Electric Cooperative, Inc. And City of Bryan v. Public Utility Commission of Texas Consumer Owned Power Systems City of Houston Texas Industrial Energy Consumers State of Texas And Constellation NewEnergy, Inc./Public Utility Commission of Texas And Reliant Energy, Incorporated

This case concerns appeals from a district court's judgment affirming a Public Utility Commission (PUC) final order that set cost-of-service rates for Reliant Energy, Inc.'s transmission and distribution utility (TDU). Appellants, including Reliant Energy, Office of Public Utility Counsel, and various consumer groups, challenged the PUC's decisions on rate base calculations, return on equity, and operational expenses. The district court had largely affirmed the PUC's order, finding only one aspect to be a prohibited advisory opinion. The Court of Appeals, Third District, At Austin, reversed the district court's judgment regarding the inclusion of $107.3 million for the interconnection of Merchant Plant 4, citing a lack of substantial evidence. In all other respects, the Court of Appeals affirmed the district court's judgment and remanded the Merchant Plant 4 issue to the Commission for further proceedings.

Utility RegulationElectricity RatesPublic Utility CommissionCost-of-ServiceRate BaseReturn on EquityConsolidated Tax SavingsTransmission and Distribution UtilityAppellate ReviewAdministrative Law
References
38
Case No. 03-03-00435-CV
Regular Panel Decision
Jul 29, 2004

Texas Workers' Compensation Commission Richard Reynolds, in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission/East Side Surgical Center Clinic for Special Surgery And Surgical and Diagnostic Center, L.P. v. East Side Surgical Center Clinic for Special Surgery/Texas Workers' Compensation Commission Richard Reynolds, in His Official Capacity as Executive Director of the Texas Workers' Compensation Commission

This case involves the Texas Workers’ Compensation Commission's failure to establish fee guidelines for ambulatory surgical centers under the Texas Workers’ Compensation Act. East Side Surgical Center, Clinic for Special Surgery, and intervenor Surgical and Diagnostic Center, L.P. (collectively "East Side") sued the Commission to invalidate certain default rules that applied when specific guidelines were absent. The district court declared one rule (133.304(i)) invalid and enjoined its enforcement, citing unlawful delegation of authority. On appeal, the Court of Appeals reversed the district court's judgment regarding the rule's invalidity and dissolved the injunction, citing a Texas Supreme Court decision finding no unlawful delegation. The court affirmed that East Side was not entitled to its usual and customary fee in the absence of specific guidelines.

Workers' CompensationAdministrative LawDelegation of AuthorityRulemakingAmbulatory Surgical CentersJudicial ReviewInsurance CarrierFee GuidelinesFair and Reasonable RatesStatutory Interpretation
References
38
Case No. 342 S.W. 2d 555
Regular Panel Decision
Feb 01, 1961

Texas Employment Commission v. Amlin

This case addresses whether employees of Big Smith Manufacturing Company were eligible for unemployment benefits after a two-week plant shutdown, during which work was unavailable and some employees received no vacation pay based on seniority. The union agreement dictated vacation terms, and while employees were ready and willing to work, the plant was closed. The Texas Employment Commission initially denied benefits, but the Court of Civil Appeals reversed, a decision upheld by the Supreme Court of Texas. The Supreme Court affirmed that the claimants did not voluntarily leave their employment without good cause, consistent with previous companion cases, thereby entitling them to unemployment compensation. The decision clarified the interpretation of the 'voluntarily without good cause' disqualification under the Texas Unemployment Compensation Act regarding union-negotiated shutdowns.

Unemployment BenefitsVacation PayPlant ShutdownUnion AgreementSeniorityDisqualification CriteriaVoluntary LeavingGood CauseTexas Unemployment Compensation ActCollective Bargaining
References
6
Case No. MISSING
Regular Panel Decision

Reliant Energy, Inc. v. Public Utility Commission

This case concerns an appeal from a district court's judgment affirming a Public Utility Commission order that set cost-of-service rates for Reliant Energy, Inc.'s transmission and distribution utility. Several parties, including Reliant, challenged the Commission's decisions on rate base, rate of return, expenses, and rate design. The court reversed the district court's judgment regarding the Commission's inclusion of $107.3 million for the Merchant Plant 4 interconnection costs, deeming it unsupported by substantial evidence. However, the court affirmed the district court's judgment in all other respects, finding the Commission's decisions on issues like consolidated tax savings, vegetation control costs, return on equity, and various rate design elements to be reasonable and supported by evidence. The case was remanded to the Commission for further proceedings consistent with the partial reversal.

Public Utility CommissionRate-settingCost-of-service ratesTransmission and distribution utilityReliant EnergyUnbundled cost of serviceRate baseReturn on equityConsolidated tax savingsVegetation control costs
References
41
Case No. 15-25-00013-CV
Regular Panel Decision
May 07, 2025

State of Texas, the Texas Facilities Commission, the Texas Health and Human Services Commission, Mike Novak, in His Official Capacity as Executive Director of the TFC, and Rolland Niles, in His Official Capacity as Deputy Executive Commissioner for the System Support Services Division of the Texas Health and Human Services Commission v. Broadmoor Austin Associates, a Texas Joint Venture

Broadmoor Austin Associates leased office space to the Texas government, specifically the Texas Health and Human Services Commission (HHSC), through the Texas Facilities Commission (TFC). Rent has been unpaid for nearly two years due to alleged misconduct by state officials. Broadmoor asserts that sovereign immunity does not bar its claims for breach of contract, citing Chapter 114's express waiver for contracts involving construction and related services. Additionally, Broadmoor brings ultra vires claims against TFC Executive Director Mike Novak and HHSC Deputy Executive Commissioner Roland Niles, alleging their actions were beyond legal authority or a failure to perform ministerial duties. Broadmoor seeks prospective injunctive and declaratory relief to ensure these officials comply with state law, specifically regarding the availability of appropriated funds for the lease.

Sovereign ImmunityBreach of ContractUltra Vires DoctrineState AgenciesGovernment ContractsLease AgreementsLegislative AppropriationsExecutive AuthorityJudicial ReviewTexas Facilities Commission
References
69
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