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Keywords

hearingdue processtariff

appealregulationdue processrespondenttariff

Related Cases

Jackson v. Metropolitan Edison Co., 419 U.S. 345, 95 S.Ct. 449, 42 L.Ed.2d 477, 8 P.U.R.4th 1

Facts

Catherine Jackson, a resident of York, Pennsylvania, had her electric service terminated by Metropolitan Edison Co. due to alleged nonpayment. After her account was closed, service was transferred to another occupant, James Dodson, who also failed to pay. When Dodson left, Jackson requested the service be transferred back to her name, but without further notice, the utility disconnected her service. Jackson claimed this termination violated her rights under the Fourteenth Amendment, as she was not given notice or a hearing.

Petitioner Catherine Jackson is a resident of York, who has received electricity in the past from respondent. Until September 1970, petitioner received electric service to her home in York under an account with respondent in her own name. When her account was terminated because of asserted delinquency in payments due for service, a new account with respondent was opened in the name of one James Dodson, another occupant of the residence, and service to the residence was resumed.

Issue

Whether the termination of Jackson's electric service by Metropolitan Edison Co. constituted 'state action' under the Fourteenth Amendment, thereby requiring due process protections.

Rule

The mere fact that a private utility is heavily regulated by the state does not convert its actions into state action for purposes of the Fourteenth Amendment. There must be a sufficiently close nexus between the state and the challenged action.

The mere fact that a business is subject to state regulation does not by itself convert its action into that of the State for purposes of the Fourteenth Amendment.

Analysis

The Supreme Court analyzed the relationship between the state and Metropolitan Edison Co., concluding that the utility's actions were not sufficiently connected to the state to constitute state action. The Court noted that while the utility was regulated, this alone did not make its termination of service attributable to the state. The Court distinguished this case from others where state action was found, emphasizing that the utility's decision to terminate service was made independently and in accordance with its tariff.

The Court noted that while the utility was regulated, this alone did not make its termination of service attributable to the state. The Court distinguished this case from others where state action was found, emphasizing that the utility's decision to terminate service was made independently and in accordance with its tariff.

Conclusion

The Supreme Court affirmed the lower court's decision, concluding that the actions of Metropolitan Edison Co. in terminating Jackson's service did not amount to state action under the Fourteenth Amendment.

The judgment of the Court of Appeals for the Third Circuit is therefore Affirmed.

Who won?

Metropolitan Edison Co. prevailed in the case because the Supreme Court found that its actions did not constitute state action, thus not subject to the requirements of due process under the Fourteenth Amendment.

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