In the 1983 case Aluminum Company of America et al. v. Central Lincoln Peoples' Utility District et al., the U.S Supreme Court ruled on a dispute between private utility companies and public utility districts over power allocation from federal hydroelectric projects in Oregon. The Bonneville Power Administration (BPA), which was responsible for marketing this power, had entered into contracts with both types of utilities that included "curtailment" provisions allowing BPA to reduce deliveries during times of shortage proportionately among all customers. However, when an energy crisis occurred in 1973, BPA interpreted its contracts differently and curtailed more power to private utilities than public ones based on their ability to acquire alternative sources of electricity at lower costs compared to public utilities. The court held that BPA's interpretation was inconsistent with the contractual language and violated statutory requirements under Federal Columbia River Transmission System Act by discriminating against particular customers without reasonable grounds. It also rejected arguments made by Alcoa claiming it should be exempted from curtailments due to its status as a direct-service industrial customer rather than a traditional utility company.

In the dissenting opinion for Aluminum Company of America et al. v. Central Lincoln Peoples' Utility District et al., Justice O'Connor disagreed with the majority's interpretation of Section 210 of the Public Utility Regulatory Policies Act (PURPA). She argued that PURPA does not require utilities to purchase power from qualifying facilities at rates exceeding their incremental cost, which is contrary to what was decided by the majority. According to her, this misinterpretation could lead to a significant increase in electricity costs for consumers and potentially undermine energy conservation efforts. Furthermore, she contended that such an approach contradicts Congress’s intent when it enacted PURPA - promoting alternative energy sources without burdening consumers with excessive costs.