The California Supreme Court issued an order Sept. 3 modifying its August 7, 2025 opinion in *Center for Biological Diversity, Inc. v. Public Utilities Commission*, a case that examined the scope of judicial review over utility regulatory decisions involving Pacific Gas and Electric Company.
The court granted a modification request filed Aug. 22, 2025, making two specific technical corrections to the original opinion without affecting the underlying judgment. The case, designated S283614, originated from the First Appellate District, Division Three under case number A167721 and concerns California Public Utilities Commission Decision No. 22-12-056.
The environmental organization Center for Biological Diversity served as the primary petitioner challenging a PUC decision that involved Pacific Gas and Electric Company and other utilities as real parties in interest. The case appears to center on questions of regulatory interpretation and the appropriate standard courts should apply when reviewing utility commission decisions.
The first modification corrected a statutory citation on page 15 of the slip opinion. The court changed the citation to read: "(§§ 1757.1, subd. (a), 1757, subd. (a); see Code Civ. Proc., § 1094.5.)" The correction involves references to sections of the Public Utilities Code and the Code of Civil Procedure section governing administrative mandamus proceedings.
The second modification addressed a more substantive clarification regarding judicial review standards. The court modified the first sentence of a paragraph on page 17 to clarify the inquiry courts must perform under amended utility code provisions. The revised language states: "At bottom, we see no reason to conclude that a court performing the inquiry required by the amended version of section 1757, subdivision (a) or section 1757.1, subdivision (a) should employ the same inquiry prescribed under preamendment law."
The modification further clarifies that under previous law, "the [C]ommission's interpretation of the Public Utilities Code" had to be upheld "unless [that interpretation] fails to bear a reasonable relation to statutory purposes and language." This language suggests the court was addressing how amendments to utility code sections may have changed the deference courts owe to PUC interpretations of regulatory statutes.
Justice Leondra Kruger authored the unanimous opinion, joined by Chief Justice Patricia Guerrero and Justices Carol Corrigan, Goodwin Liu, Joshua Groban, Kelli Evans and Martin Jenkins. The unanimous nature of the decision suggests broad agreement among the justices on the legal principles involved in reviewing utility regulatory decisions.
The case reflects ongoing tensions between environmental advocacy groups and utility regulators over energy policy decisions. Environmental organizations like the Center for Biological Diversity frequently challenge utility commission decisions they view as insufficiently protective of environmental interests or contrary to statutory mandates.
The technical nature of the modifications suggests the original opinion may have contained ambiguities regarding the proper standard of judicial review that could have created confusion for lower courts. By clarifying that amended statutory provisions may require different analytical approaches than previous law, the court appears to be providing guidance on how courts should evaluate PUC decision-making going forward.
The reference to Code of Civil Procedure section 1094.5 is significant because this provision governs judicial review of administrative agency decisions through administrative mandamus proceedings. This type of review allows courts to examine whether agencies have proceeded without jurisdiction, failed to afford a fair trial, or made decisions not supported by findings.
While the specific underlying dispute between the environmental groups and the utility commission remains unclear from the modification order, the case appears to involve fundamental questions about regulatory authority and environmental protection in utility operations. The involvement of Pacific Gas and Electric Company, California's largest utility, suggests the decision could have broad implications for energy regulation statewide.
The timing of the modification, coming nearly a month after the original opinion and following a party's request, indicates that stakeholders identified potential confusion in the court's original language that needed clarification. Such modifications are relatively common when complex regulatory cases involve intricate statutory interpretation that affects future litigation.
The court's emphasis that the modifications do not affect the judgment suggests the core holding of the case remains intact, with the changes serving primarily to eliminate ambiguity rather than alter substantive legal conclusions. This approach allows the court to provide clearer guidance to lower courts and practitioners while maintaining the integrity of its original decision.
The case represents another example of the California Supreme Court's ongoing role in clarifying the boundaries between judicial and administrative authority in the highly regulated utility sector, where environmental considerations increasingly intersect with traditional rate-setting and service provision concerns.