Ohio Bell Telephone Co. v. Public Utilities Commission

The Public Utilities Commission (PUC) (defendant) set 1925 telephone rates for Ohio Bell (plaintiff) based on evidence from administrative hearings, but then set rates for 1926-1933 by taking official notice of undisclosed price trends drawn from property taxes, construction indexes, and unrelated court findings, without including that data in the record or giving Ohio Bell any chance to respond. The resulting rates required Ohio Bell to issue significant customer refunds, and Ohio Bell challenged the order; the Ohio Supreme Court affirmed, and the U.S. Supreme Court granted certiorari.