Jackson v. Metropolitan Edison Co.
Public utilities, like electric companies, are often regulated heavily by governmental authorities. However, does that regulation mean that someone who has a utility shut off should be entitled to due process rights as if it was a governmental agency turning off the utility? That is the question that the Supreme Court decided in Jackson v. Metropolitan Edison Co.. In this case, a Pennsylvania electric company fought to be treated as a private company rather than as a public agency in order to have an easier time shutting off electric service for non-payment.
Jackson's Electric Service
Catharine Jackson lived in York, Pennsylvania in the 1970s. Jackson's electric service was shut down by Metropolitan Edison Co., her local private electric company that was highly regulated by the state of Pennsylvania. A roommate paid the electric for some time after Jackson's delinquent payments resulted in the shutdown. However, that roommate eventually left the residence and stopped paying any electric bill as well. Once the electric company found out that the roommate no longer lived in the residence, they would have shut off Jackson's service, except that she transferred it to her son's name.
This would have been the end of the story, except for one thing: Jackson's son was only 12 years old, much too young to be able to be considered competent for the purposes of forming a valid contract. The contract was unenforceable, and as soon as Metropolitan Edison Co. found out that a 12 year old was the person signed up for power, it cut the power at Jackson's residence.
Jackson v. Metropolitan Edison Co. began when Jackson sued in federal district court, saying that the Metropolitan Edison Co., because it operated as a monopoly with extensive government oversight, was acting as an actual governmental agency. She sued asking for injunctive relief, asking for her power to be switched back on until she had been provided due process in the form of a hearing to determine whether her power bills had gone unpaid and a reasonable opportunity to pay any bills that were discovered to be delinquent.
The District Court for the Middle District of Pennsylvania was the court that heard the case initially, but Metropolitan Edison immediately made a motion to dismiss. Metropolitan Edison said that because they were a privately owned company, they had no obligation to provide judicial review of decisions as part of Jackson's due process rights.
Appeal and Supreme Court Ruling
The Third Circuit Court of Appeals affirmed the ruling that the District Court had laid out, noting that there is a significant difference between a state actor and an agency regulated by the state. Jackson v. Metropolitan Edison Co. was granted certiorari by the Supreme Court of the United States and was decided at the end of 1974. The Supreme Court, in a 6-3 ruling, decided that there had been no state action when Metropolitan Edison cut Jackson's power and that she was not entitled to any form of judicial hearing before her power could be discontinued for lack of payment.