Citizens of the State of Florida, Appellant v. Art Graham

Summary

The court reversed the Florida Public Service Commission's approval of recovery through the fuel clause of costs associated with a utility's transmission interconnection project. It held that the issue was preserved, that the Commission unlawfully failed to analyze the governing settlement agreement, that construction-related transmission costs were not recoverable through the fuel clause, and that the settlement agreement prohibited their recovery. Justice Canady, dissenting, would have affirmed because he viewed the agreement as barring only increases in existing costs and found competent, substantial evidence supporting recovery.