Data Foundry, Inc. v. City of Austin, Texas

CourtTexas Supreme Court
DecidedApril 9, 2021
Docket19-0475
StatusPublished

This text of Data Foundry, Inc. v. City of Austin, Texas (Data Foundry, Inc. v. City of Austin, Texas) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Data Foundry, Inc. v. City of Austin, Texas, (Tex. 2021).

Opinion

IN THE SUPREME COURT OF TEXAS ════════════ NO. 19-0475 ════════════

DATA FOUNDRY, INC., PETITIONER,

v.

CITY OF AUSTIN, TEXAS, RESPONDENT

══════════════════════════════════════════════════ ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS ══════════════════════════════════════════════════

Argued December 3, 2020

JUSTICE HUDDLE delivered the opinion of the Court.

The City of Austin, through its city council, sets the rates that Austin Energy, an electric

utility owned by the City, charges to Austin residents for retail electric services. Data Foundry,

Inc., an internet service provider, purchases electricity from Austin Energy for its facilities in

Austin. Data Foundry alleges that the rates charged by the City are illegal, and it filed a lawsuit to

challenge those rates. The City filed a motion to dismiss under Texas Rule of Civil Procedure 91a.

The trial court granted the motion on the sole ground that Data Foundry lacked standing because

it failed to allege it had suffered a particularized injury. The court of appeals concluded Data

Foundry suffered a particularized injury sufficient to confer standing but affirmed the dismissal of

Data Foundry’s claims in part on other grounds. We conclude that Data Foundry has standing to

bring its claims, and we remand the case to the trial court. I Data Foundry is an internet service provider that operates data centers located within the

boundaries of the City of Austin. The City owns and operates Austin Energy, an electric utility

system, as authorized by statute. TEX. LOC. GOV’T CODE § 552.001(b). Like many utility systems,

Austin Energy has traditionally operated as a monopoly; any City resident wishing to purchase

electric services must obtain those services from Austin Energy. The City sets the rates that Austin

Energy charges to retail customers through rate ordinances passed by the Austin City Council.

In 2016, Austin Energy proposed to change the retail rates it was charging for electric

services. The City hired a hearing examiner to conduct a review of the proposed new rates. Several

ratepayers, including Data Foundry, intervened and participated in the hearing process. Ratepayers

were permitted to conduct discovery, provide testimony, and cross-examine witnesses at a public

hearing. Data Foundry submitted briefs in which it argued, as it does here, that Austin Energy’s

proposed rate structure would result in rates that were unreasonable, unlawful, and confiscatory.

In particular, Data Foundry asserted that it was improper for Austin Energy to recoup losses

resulting from its power-generation operations (over $200 million, according to Data Foundry)

through the rates it charges to captive retail customers. Ultimately, the Austin City Council

rejected Data Foundry’s arguments and passed an ordinance establishing new “base” charges and

various “pass-through” charges that Austin Energy would charge to retail customers of electric

services.

Data Foundry sued in district court, seeking declarations that (1) the ordinance is “illegal

and unenforceable” because the rates prescribed therein are “unjust, unreasonable, excessive,

discriminatory, constitute a taking, are confiscatory and do not reflect a reasonable measure of use

by or benefit to ratepayers”; (2) the rates lead to “an excessive and unreasonable return or profit”; 2 (3) the Austin City Council acted arbitrarily and capriciously and abused its discretion by

promulgating the rates; (4) the rates are discriminatory; and (5) the rates constitute an illegal tax.

Data Foundry also sought to enjoin enforcement of the ordinance.

The City filed a motion to dismiss all of Data Foundry’s claims under Rule 91a.1 The City

asserted two grounds for dismissal: (1) Data Foundry failed to allege a particularized injury

sufficient to confer standing; and (2) alternatively, Data Foundry’s claims have no basis in law.

The trial court granted the City’s motion and dismissed the suit. The court’s dismissal order states

the motion was granted on the ground that Data Foundry lacked standing to assert its claims. Data

Foundry appealed.

The parties’ briefs in the court of appeals focused on the trial court’s holding that Data

Foundry lacked standing because it failed to allege it had suffered a “particularized injury.”

However, Amici Curiae CPS Energy and Texas Public Power Association submitted in the court

of appeals a brief in which they asserted the Public Utility Regulatory Act (PURA)2 “supersedes

any common law rules regarding whether and how courts review municipal utility rates.” Amici

argued that, under PURA, resident ratepayers have no basis for seeking judicial review of the rates

set by a municipally owned utility. Amici also argued that Data Foundry’s suit, if allowed to

proceed, would require the courts to interfere with decisions that are exclusively within the control

of the City. In particular, they argued Data Foundry’s suit, if successful, would bar the City from

adopting retail rates designed to recover its power-generation costs, and doing so would

impermissibly force the City to “unbundle” Austin Energy’s retail operations from its generation

1 Rule 91a provides that, subject to certain exceptions not applicable here, “a party may move to dismiss a cause of action on the grounds that it has no basis in law or fact.” TEX. R. CIV. P. 91a.1. 2 TEX. UTIL. CODE §§ 11.001–66.016. 3 operations. To put this argument in proper context requires a brief discussion of the relevant

statutes.

Before electricity can be furnished to customers, it must be produced, generated,

transmitted, distributed, and ultimately sold to the customer. Electric utility companies

traditionally have operated as monopolies in the areas they serve, providing all these services for

a particular municipality or other geographic area. See TEX. UTIL. CODE § 31.001(b). In 1999,

however, the Texas Legislature made sweeping changes to the Texas Utilities Code with the

purpose of restructuring certain electric utility services. See generally Act of May 27, 1999, 76th

Leg., R.S., ch. 405, 1999 Tex. Gen. Laws 2543. Among other things, the 1999 amendments

required each “electric utility” to “unbundle,” that is, to separate its business activities into three

separate units: a power generation company, a retail electric provider, and a transmission and

distribution utility. Id. § 39 (codified at TEX. UTIL. CODE § 39.051(b)).

Significantly, however, municipally owned utilities (such as Austin Energy) are excluded

from this unbundling mandate. See TEX. UTIL. CODE § 40.001(a) (stating that, with respect to

municipally owned utilities, Chapter 40 controls over any other Utilities Code provision, except

where the term “municipally owned utility” is specifically used); see also id. § 31.002(6)

(excluding municipal corporations from the definition of “electric utility”). Chapter 40 gives the

municipal governing body of a municipally owned utility “exclusive jurisdiction” to “determine

whether to unbundle any energy-related activities and, if the municipally owned utility chooses to

unbundle, whether to do so structurally or functionally.” Id. § 40.055(a)(2).

The City of Austin has not chosen to unbundle Austin Energy’s energy-related activities,

nor is it obligated to do so. However, amici argued in the court of appeals that Data Foundry’s

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Data Foundry, Inc. v. City of Austin, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/data-foundry-inc-v-city-of-austin-texas-tex-2021.