Peoples Energy Corp. v. Illinois Commerce Commission

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting doctrine of primary jurisdiction is not technically a question of jurisdiction at all but rather a question of judicial self-restraint and relations between the courts and administrative agencies
• mere sale of electricity does not render seller a utility; public utility implies public use and duty to serve the public without discrimination
• “The general rule ... is that holding companies and their subsidiaries are separate legal entities.”
• actual controversy arose where agency sent corporation a citation directing corporation to appear before it to argue either that the agency lacked jurisdiction over the company’s corporate reorganization or that the reorganization was in the public interest

Source: CourtListener parenthetical corpus (CC0).