As a slap in the face to California Gov. Gray "out" Davis, a federal administrative law judge ruled that California actually owed money after the 2000-2001 energy crisis. The New York Times notes that "the Federal Energy Regulatory Commission, ruled that energy companies overcharged California about $1.8 billion during the crisis, but said the state had an unpaid balance of $3 billion and thus owed $1.2 billion."

California had claimed that they were owed $9 billion in refunds.