Williamson v. Montana Public Service Commission

A group of individuals filed an administrative action with the Montana Public Service Commission concerning an electric utility company’s provision of street lighting services. Specifically, the plaintiffs sought to have the Commission require the utility company to replace existing street lights with light emitting diode (LED) street lights, contending that adoption of LEDs would, among other things, reduce greenhouse gas emissions. The Commission denied the petition, stating that while LED technology was promising, it did not warrant a mandatory street and outdoor lighting conversion program. The individuals subsequently filed an action in state court, which dismissed on standing grounds. On appeal, the Montana Supreme Court reversed in part, holding that although the individuals named in the original complaint lacked standing because they failed to establish that they were directly affected by the Commission’s decision not to require LED lights, an amended complaint naming individuals who were directly affected established standing. Thus, the court remanded the case to the Commission to determine whether to allow the amended complaint.