Washington Supreme Court
Waste Management of Seattle, Inc. v. the Utilities and Transportation Commission
March 17, 1994123 Wash. 2d 621
Summary
The court held that the disposal-fee statute unambiguously requires the Commission to include qualifying disposal charges in a solid waste company's permanent rates, subject only to determining whether the charges fall within the statute. The Commission could substantively review the charges under the affiliated-interest statute only if they arose from a direct contract or arrangement between the regulated company and its affiliate, which was absent here. The court also held that appellate review of agency adjudications proceeds on the agency record rather than the superior court's findings and conclusions.