The Ohio Supreme Court issued a unanimous decision affirming that the Public Utilities Commission of Ohio holds exclusive subject-matter jurisdiction over claims brought by natural gas producers against Dominion Energy Ohio in a class action lawsuit. The ruling, issued Jan. 14, 2026, upholds a Court of Appeals decision that removed the case from common pleas court.
In *East Ohio Gas Company v. Croce* (2026-Ohio-75), the high court addressed the jurisdictional boundaries between Ohio's utility regulatory framework and traditional civil litigation. The case involved natural gas producers who filed a class action against East Ohio Gas Company, which operates as Dominion Energy Ohio, and sought to have their claims heard in Summit County Common Pleas Court.
The Supreme Court applied established precedent from *Allstate Insurance Company v. Cleveland Electric Illuminating Company* and Ohio Revised Code Section 4905.26 to determine that utility-related disputes must be resolved through the specialized administrative process rather than traditional court proceedings. This framework ensures that complex utility matters are handled by regulators with specific expertise in the energy sector.
The Court of Appeals for Summit County initially granted summary judgment in favor of the public utility and ordered the common pleas court judge to cease exercising jurisdiction over the class action. The appeals court also directed the trial judge to vacate all orders previously issued in the case, effectively transferring the matter to PUCO's exclusive authority.
The natural gas producers, represented by Landmark 2 Limited Liability Company and other appellants, challenged this jurisdictional determination before the Ohio Supreme Court. However, the state's highest court found no error in the appeals court's conclusion that PUCO possesses exclusive jurisdiction over the claims asserted by the producers.
This decision reflects Ohio's comprehensive regulatory scheme for public utilities, which grants PUCO broad authority over utility operations, rates, and service disputes. The commission's exclusive jurisdiction prevents forum shopping and ensures that utility-related matters are resolved by regulators familiar with the technical and economic complexities of energy markets.
The case demonstrates the tension between private parties seeking traditional court remedies and the state's interest in maintaining centralized regulatory oversight of public utilities. Natural gas producers often have contractual or operational disputes with utility companies that involve complex industry-specific issues requiring specialized knowledge to resolve effectively.
Dominion Energy Ohio, formerly known as East Ohio Gas Company, is a major natural gas distribution utility serving customers throughout Ohio. The company's operations fall squarely within PUCO's regulatory purview, making it subject to the commission's comprehensive oversight authority.
The Supreme Court's per curiam opinion was joined by all seven justices: Chief Justice Kennedy and Justices Fischer, DeWine, Brunner, Deters, Hawkins, and Shanahan. This unanimous decision strengthens the precedential value of the ruling and provides clear guidance for future cases involving utility jurisdiction questions.
The ruling has significant implications for how utility-related disputes are litigated in Ohio. Private parties with claims against public utilities must now direct their complaints to PUCO rather than seeking relief through traditional civil litigation. This ensures that utility disputes receive specialized regulatory review while preventing potential conflicts between court orders and commission decisions.
For natural gas producers operating in Ohio, the decision clarifies the proper forum for addressing grievances against utility companies. Rather than pursuing class action lawsuits in common pleas court, producers must work within PUCO's established administrative procedures to seek relief.
The case also reinforces PUCO's role as the primary guardian of Ohio's utility regulatory framework. By maintaining exclusive jurisdiction over utility disputes, the commission can ensure consistent application of state energy policy and prevent potentially conflicting decisions from multiple courts.
Legal practitioners representing clients with utility-related claims must now ensure their cases are filed with PUCO rather than traditional courts. Failure to recognize the commission's exclusive jurisdiction could result in dismissal and require refiling before the appropriate regulatory body.
The decision builds upon Ohio's long-established principle that specialized administrative agencies possess exclusive jurisdiction over matters within their regulatory expertise. This approach promotes efficiency and consistency in utility regulation while ensuring that complex technical issues receive appropriate expert review.
Moving forward, the ruling provides clear direction for resolving utility disputes in Ohio and reinforces the boundaries between regulatory oversight and traditional civil litigation. Natural gas producers and other parties with utility-related claims now have definitive guidance on the proper forum for seeking relief against public utility companies operating under PUCO's jurisdiction.