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The U.S. Supreme Court case Arkansas Electric Cooperative Corp. v. Arkansas Public Service Commission in 1982 revolved around the issue of whether a state could regulate the wholesale rates charged by an electric cooperative that was owned and operated by its consumers, even though those rates had already been approved at federal level by the Federal Power Commission (FPC). The court ruled in favor of the Arkansas Electric Cooperative Corporation (AECC), stating that states do not have jurisdiction over interstate sales for resale of electricity, which are subject to exclusive regulation by FPC under Federal Power Act's scheme for regulating sale of electric energy at wholesale in interstate commerce. Therefore, AECC’s federally-approved rate schedules preempted any attempt from state commission to impose lower ones.
In the dissenting opinion for Arkansas Electric Cooperative Corp. v. Arkansas Public Service Commission, Justice Blackmun argued that the majority's decision was a misinterpretation of federal law and an overreach into state regulatory affairs. He contended that Congress had not intended to exempt rural electric cooperatives from all forms of state regulation when it passed the Rural Electrification Act (REA). Instead, he believed that such exemptions should be limited to those specifically mentioned in the REA or other relevant federal statutes. According to him, allowing states some degree of control would better serve public interest by promoting competition and preventing monopolistic practices among power suppliers. Furthermore, he criticized the majority's reliance on legislative history as inconsistent with previous court decisions which favored statutory text over congressional intent.