The Public Service Commission of the State of New York v. Mid-Louisiana Gas Co. et al., 1982, was a case that revolved around the Federal Power Act (FPA) and Natural Gas Act (NGA). The Supreme Court had to decide whether or not these acts allowed for retroactive rate adjustments by federal regulatory agencies. The court ruled in favor of Mid-Louisiana Gas Co., stating that neither act permitted such retroactive adjustments. This decision upheld the filed-rate doctrine, which maintains that utility companies can only charge rates approved by relevant regulatory bodies and those rates cannot be changed retrospectively.

In the dissenting opinion for Public Service Commission of the State of New York v. Mid-Louisiana Gas Co., Justice William Rehnquist disagreed with the majority's interpretation of the Natural Gas Policy Act (NGPA). He argued that Congress intended to give Federal Energy Regulatory Commission (FERC) authority over all sales, including first sales, and not just interstate pipeline sales as interpreted by the majority. The NGPA was enacted to address a natural gas shortage crisis and aimed at encouraging production through deregulation while protecting consumers from price exploitation. According to Rehnquist, excluding first-sale transactions would undermine this purpose because it leaves a significant portion of natural gas market unregulated which could lead to price manipulation and consumer harm. Furthermore, he pointed out that FERC had been exercising jurisdiction over these transactions without any objections from Congress implying its approval. Therefore, in his view, FERC should have jurisdiction over both intrastate first-sales and interstate pipeline sales under NGPA.