Huntington Sanitary Board v. Public Service Commission of West Virginia and Hubbard Heights Subdivision Association

CourtWest Virginia Supreme Court
DecidedMay 23, 2025
Docket24-637
StatusPublished

This text of Huntington Sanitary Board v. Public Service Commission of West Virginia and Hubbard Heights Subdivision Association (Huntington Sanitary Board v. Public Service Commission of West Virginia and Hubbard Heights Subdivision Association) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Huntington Sanitary Board v. Public Service Commission of West Virginia and Hubbard Heights Subdivision Association, (W. Va. 2025).

Opinion

IN THE SUPREME COURT OF APPEALS OF WEST VIRGINIA

FILED January 2025 Term May 23, 2025 released at 3:00 p.m. C. CASEY FORBES, CLERK SUPREME COURT OF APPEALS OF WEST VIRGINIA No. 24-637

HUNTINGTON SANITARY BOARD, Petitioner,

v.

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA and HUBBARD HEIGHTS SUBDIVISION ASSOCIATION, et al., Respondents.

Appeal from the Public Service Commission of West Virginia Case No. 23-0010-S-DU

AFFIRMED

Submitted: March 18, 2025 Filed: May 23, 2025

Ancil Ramey, Esq. Jessica M. Lane, Esq. Steptoe & Johnson PLLC Susan M. Stewart, Esq. Huntington, West Virginia Public Service Commission of West Todd M. Swanson, Esq. Virginia Steptoe & Johnson PLLC Charleston, West Virginia Charleston, West Virginia Counsel for Respondent Public Service Counsel for Petitioner Commission

Robert R. Rodecker, Esq. John R. McGhee, Jr., Esq. Cynthia L. Wilson, Esq. Kay Casto & Chaney PLLC Charleston, West Virginia Counsel for Amicus Curiae City of Elkins and Town of Harman

F. Paul Calamita, Esq. AQUALAW PLC Richmond, Virginia Counsel for Amicus Curiae West Virginia Municipal Water Quality Association

JUSTICE WALKER delivered the Opinion of the Court.

JUSTICE TRUMP deeming himself disqualified did not participate in the decision.

JUDGE DYER sitting by temporary assignment. SYLLABUS BY THE COURT

1. “‘The detailed standard for our review of an order of the Public

Service Commission contained in Syllabus Point 2 of Monongahela Power Co. v. Public

Service Commission, 166 W. Va. 423, 276 S.E.2d 179 (1981), may be summarized as

follows: (1) whether the Commission exceeded its statutory jurisdiction and powers; (2)

whether there is adequate evidence to support the Commission’s findings; and, (3) whether

the substantive result of the Commission’s order is proper.’ Syl. Pt. 1, Cent. W. Va. Refuse,

Inc. v. Pub. Serv. Comm’n of W. Va., 190 W.Va. 416, 438 S.E.2d 596 (1993).” Syllabus

Point 2, Sierra Club v. Pub. Serv. Comm’n of West Virginia, 241 W. Va. 600, 827 S.E.2d

224 (2019).

2. “The Public Service Commission of West Virginia has no jurisdiction

and no power or authority except as conferred on it by statute and necessary implications

therefrom, and its power is confined to the regulation of public utilities. It has no inherent

power or authority.” Syllabus Point 2, Wilhite v. Pub. Serv. Comm’n, 150 W. Va. 747, 149

S.E.2d 273 (1966).

3. “Where the transmission line of a public utility has been used directly

to serve retail rural consumers over a long period of time, such use constitutes a dedication

of that line to the public service and such facility will continue to be so dedicated and the

owner thereof will continue to operate as a public utility unless and until permission is

i obtained from the Public Service Commission to terminate such status.” Syllabus Point 3,

Boggs v. Pub. Serv. Comm’n, 154 W. Va. 146, 174 S.E.2d 331 (1970).

4. “Jurisdiction of the Public Service Commission over a public utility

will not be considered to be terminated unless the action of the Commission and the

circumstances surrounding the case demonstrate clearly and unequivocally its intent to

relinquish such jurisdiction.” Syllabus Point 1, Boggs v. Pub. Serv. Comm’n, 154 W. Va.

146, 174 S.E.2d 331 (1970).

5. “The mere failure of a public utility to invoke the jurisdiction or the

regulatory power of the Public Service Commission for a long period of time, or the mere

failure of the Commission affirmatively to assert in any manner its jurisdiction with respect

to the public service rendered does not divest the utility of its original status as a public

utility.” Syllabus Point 4, Boggs v. Pub. Serv. Comm’n, 154 W. Va. 146, 174 S.E.2d 331

(1970).

6. “‘The principle is well established by the decisions of this Court that

an order of the public service commission based upon its finding of facts will not be

disturbed unless such finding is contrary to the evidence, or is without evidence to support

it, or is arbitrary, or results from a misapplication of legal principles.’ United Fuel Gas

Company v. Public Service Commission, 143 W.Va. 33 [99 S.E.2d 1 (1957)].” Syllabus

Point 5, Boggs v. Pub. Serv. Comm’n, 154 W. Va. 146, 174 S.E.2d 331 (1970).

ii WALKER, Justice:

The Distressed and Failing Utilities Act1 directs the Public Service

Commission of West Virginia (PSC) to remediate struggling utilities such as sewer districts.

The sewer system of Hubbard Heights subdivision in Wayne County is one such failing

utility, and Petitioner Huntington Sanitary Board (HSB) was designated by the PSC as the

most suitable capable proximate utility (CPU) to acquire and resume its operations under

West Virginia Code § 24-2H-7(a) (2020). On appeal of the PSC’s order to that effect, HSB

argues that the PSC lacks jurisdiction over this small failing utility because its customer

base fell below twenty-five, the threshold for PSC jurisdiction under West Virginia Code §

24-2-1(a)(8) (2023). HSB also challenges its designation as the most suitable CPU, citing

logistical and financial concerns. Because we find that the PSC appropriately exercised

continuing jurisdiction over Hubbard Heights and that it gave reasoned consideration to all

statutory requirements before ordering HSB to acquire this failing utility, we affirm.2

I. FACTUAL AND PROCEDURAL BACKGROUND

Hubbard Heights is a subdivision located in Wayne County. Its sewer system

consists of septic tanks at each residence that feed into the main sewer, eventually feeding

1 W. Va. Code §§ 24-2H-1 to -9. 2 The Court would like to acknowledge the participation in this case of the City of Elkins, Town of Harman, and Municipal Water Quality Association, who filed briefs in support of Petitioner. The Court has considered the arguments presented in conjunction with the parties’ arguments.

1 into three treatment lagoons. In 2001, the Hubbard Heights Homeowners Association

(HOA) applied to become a sewer utility regulated by the PSC, which certificate of

convenience and necessity was granted in 2002. At the time of application, the Hubbard

Heights sewer utility was servicing twenty-seven customers. But by 2011, the HOA

stopped filing its annual reports with the PSC and the PSC initiated several proceedings

against it for failure to file its annual reports and assessed fees that were never paid. The

HOA filed a joint petition with West Virginia American Water Company for approval to

terminate water services for non-payment of sewer bills in 2013, but never filed a request

for dissolution with the PSC. The HOA was administratively dissolved as an entity by the

West Virginia Secretary of State in 2014.

In response to growing concerns with West Virginia’s water and wastewater

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Related

Monongahela Power Co. v. Public Service Comm.
276 S.E.2d 179 (West Virginia Supreme Court, 1981)
Central West Virginia Refuse, Inc. v. Public Service Commission
438 S.E.2d 596 (West Virginia Supreme Court, 1993)
Broadmoor/Timberline Apartments v. Public Service Commission
376 S.E.2d 593 (West Virginia Supreme Court, 1988)
Boggs v. Public Service Commission
174 S.E.2d 331 (West Virginia Supreme Court, 1970)
Wilhite v. Public Service Commission
149 S.E.2d 273 (West Virginia Supreme Court, 1966)
Smith v. State
241 S.E.2d 14 (Court of Appeals of Georgia, 1977)
United Fuel Gas Co. v. Public Service Commission
99 S.E.2d 1 (West Virginia Supreme Court, 1957)
Sierra Club v. Public Service Commission of West Virginia
827 S.E.2d 224 (West Virginia Supreme Court, 2019)

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