Petition of the Off. of People's Counsel

Summary

The Supreme Court of Maryland held that courts must review the Maryland Public Service Commission’s interpretation of its own prior merger order under the highly deferential arbitrary-or-capricious standard. Applying that standard, the Court upheld the Commission’s determination that Washington Gas satisfied the merger condition requiring at least $800,000 in annual net merger-related benefits, even though the company’s post-merger costs increased relative to the pre-merger baseline. The Court affirmed the judgment of the Appellate Court of Maryland.