Morgan Stanley Capital Group Inc. v. Public Utility District No. 1 of Snohomish County

Summary

The Court held that the Mobile-Sierra presumption applies to wholesale energy contracts even if filed under market-based tariffs without initial FERC review, and that the standard to overcome it is 'serious harm to the public interest' for both buyer and seller challenges. It found FERC’s analysis flawed for failing to assess excessive burden down the line and clarify market manipulation findings. Justices Stevens and Souter dissented, arguing the FPA mandates uniform just-and-reasonable review without a heightened presumption. Justice Ginsburg concurred in part and judgment, noting she would have waited for a more developed record.