The recent decision of the Supreme Court of the United States in the so-called Martinsville case has been interpreted by some critics as laying down a "municipal unit doctrine" of rate making, denying to a system utility the right to earn from its entire operations a fair return on the value of its entire property, and substituting therefor a "bundle of rights" to earn in each "municipality" served a fair return on the value of the property used and useful therefor.
Robert D. Armstrong,
THE MUNICIPALITY AS A UNIT IN RATEMAKING AND CONFISCATION CASES,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol32/iss3/2