Arizona Corp. Commission v. State ex rel. Woods

In Arizona Corp. Commission v. State ex rel. Woods, 171 Ariz. 286, 830 P.2d 807 (1992), the Attorney General refused to certify the Affiliated Interests Rules pursuant to the Administrative Procedure Act on the grounds that the Commission did not have the power to adopt the rules. Id. at 289, 830 P.2d at 810. The Commission filed a special action with the Arizona Supreme Court, which accepted jurisdiction. 171 Ariz. at 288, 830 P.2d at 809. The supreme court concluded that Article 15, Section 3 of the Arizona Constitution gave the Commission exclusive authority not only to set rates but also to enact rules and regulations that are "reasonably necessary for ratemaking," and that the court would defer to the Commission's determination as to what was reasonably necessary for rate-making. Id. at 295, 830 P.2d at 816.