The Law School Authority

Jackson v. Metro Edison Co. Case Brief

Summary of Jackson v. Metro Edison Co.
419 U. S. 345 [1974]

Govt Regulation of Private Activity

Relevant Facts: Pl’s electric service was terminated before she was provided notice, a hearing, or an opportunity to pay any amounts due.  The Df is a privately owned and operated utility corporation acted under a state regulation allowing termination.

Legal Issue(s): Whether Metropolitan’s termination of pl’s electric service, as allowed by law, should be considered a state action and subject to the limitations under the 14th ?

Court’s Holding: No

Procedure: D Ct dismissed the Pl’s action, Ct. App Affirmed, S. Ct. Affirmed.

Law or Rule(s): There must be a sufficiently close nexus between the State and the challenged action of the regulated entity so that the action of the latter may be treated as the State itself.

Court Rationale: The mere fact that a business is subject to state regulations does not itself convert its action into that of the State.  The State never granted the Df a monopoly status. The action by Metro was not a power delegated to it by the State which is traditionally a public function.  Metro does provide goods and services that affect a public interest, but their every action does not automatically convert into a state action b/c it is heavily regulated.  Metro does not have a license under State authority to act in every business decision.  The regulation of utilities dictates that the utility may be required to obtain approval for some practices in less detail than others.  Where the commission has not put its own weight on the side of the proposed practice does not equate into a state action.  Metro elected to terminate service to PL in a manner permissible under state law.

Plaintiff’s Argument: Singling out the Pl and terminating her electric service was a state action depriving her of property w/o due process of law.

Defendant’s Argument: The municipality decision is not a state action, the Pet. is heavily regulated but there is no close connection to the state itself.

No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the U. S.; nor deprive any person life, liberty, or property w/o due process of law; nor deny any person the equal protection of the law.

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