Robert Burns v. Arizona Public Service Co

Summary

The court held that each Arizona Corporation Commission commissioner independently possesses constitutional authority to investigate public service corporations and compel evidence, and that a Commission majority may not nullify that authority through its own orders or rules. It also held that an aggrieved commissioner may seek a declaration of those rights under the Uniform Declaratory Judgment Act. The court vacated the appellate decision, reversed the superior court's ruling on the issues before it, and remanded for further proceedings.