Smith v. Illinois Bell Telephone Co., 282 U.S. 133
In a suit by a public utility to enjoin, as confiscatory, an order of a state commission lowering its rates, an interlocutory injunction was granted upon the condition that, if the injunction were dissolved, the plaintiff should refund to its subscribers the amounts paid by them in excess of those chargeable under the commission's order. A large excess had accumulated when, a number of years later, a final injunction was granted. On appeal, held that, as the decree speaks from its date, the question is necessarily presented not only whether the rate order was confiscatory when made, but also as to its validity during the period that has intervened and as to the respective rights of the company and its subscribers in the funds accumulated. P. 282 U. S. 142.