Direct Energy Services, LLC v. Public Utilities Regulatory Authority

Summary

The court affirmed the judgment upholding PURA’s geographic and marketing restrictions for voluntary renewable offers. It held that both restrictions survive dormant Commerce Clause review under the Pike balancing test, that the plaintiffs’ free-speech and contract claims were not preserved because they were not raised before PURA, and that the alleged procedural defects under the UAPA did not warrant relief. The court concluded that the plaintiffs failed to establish either an impermissible interstate burden or prejudice to substantial rights.