Ariz. Corp. Comm'n v. State ex rel. Woods
In Ariz. Corp. Comm'n v. State ex rel. Woods, 171 Ariz. 286, 291, 830 P.2d 807, 812 (1992), the supreme court reexamined the preceding line of cases "critically in light of the history and text of the constitution." 171 Ariz. at 294, 830 P.2d at 815.
Woods involved a challenge to rules requiring public service corporations to "report information about, and obtain permission for transactions with, its parent, subsidiary, and other affiliated corporations." Id. at 287, 830 P.2d at 808.
In exploring the origins of and rationale for the Commission's Article 15 powers, Woods noted the founders' expectation that the Commission provide "both effective regulation of public service corporations and consumer protection against overreaching by those corporations." Id. at 290, 830 P.2d at 811.
The "strongest power" the Commission derives from the Arizona Constitution is its regulation of public service corporations. Id.