Energy Reserves Group Inc. v. Kansas Power and Light Co.
459 U.S. 400 (1983)
KPL was buying natural gas
from ERG. The contract stipulated the price, but had a clause stating
that, "if a governmental authority fixes a price for any natural gas
that is higher than the price specified in the contract, the contract
price shall be increased to that level."
At the time, the Federal
government had price controls that set a maximum price you could charge
for natural gas.
Kansas enacted a law that said
the price in existing contracts could not be increased even if the Federal
government raised the price ceiling.
The Federal government raised
the ceiling, and ERG raised their price. KPL sued.
KPL argued that the price
increase violated the Kansas State law.
ERG argued that the Kansas
law was a violation of their freedom of contract, and therefore a violation of the Contracts
Clause of the Constitution.
Article I §10 says, "No State shall pass any law
impairing the obligation of contracts."
The US Supreme Court upheld
the Kansas law.
The US Supreme Court found
that ERG's rights were not "substantially impaired" because
everyone was aware of the fact that the contract was subject to a wide
range of regulations.
The Court went on to suggest
that if there is a "substantial impairment," then the law would
still be Constitutional if "the state, in justification has a
significant and legitimate public purpose," and "whether the
adjustment of rights and responsibilities of contracting parties is based
upon reasonable conditions and is of a character appropriate to the
public purpose justifying the legislation's adoption."
In this case the Court
found that any "substantial impairment" that might exist is
outweighed by an overriding interest in consumer protection.
So basically, the holding in
this case is that the State can interfere with a contract, as long as
there is no "substantial impairment" to the parties, or (if
there is substantial impairment), if the State has a legitimate,
overriding reason and the law is
reasonable and appropriate.