Jackson v. Metropolitan Edison Co PDF

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Constitutional Law II 2020 case brief for Jackson...

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JACKSON v. METROPOLITAN EDISON CO. 419 U.S. 345 (1974) FACTS: Parties: Appellant: Catherine Jackson (Π) Appellee: Metropolitan Edison Co (Δ) Procedural History: 

District Court dismissed



Court of Appeals dismissed



Π appealed

Relevant Facts: 

Π claims her electricity was terminated before she was afforded notice, a hearing, and an opportunity to pay any amounts found due pursuant to 42 U.S.C. 1983

ISSUE: 

Whether the heavy regulation of a public utility, which is privately owned, constitutes a state action

PARTIES’ ARGUMENTS: Appellant: 

Under state law she was entitled to reasonably continuous electricity



Δ’s termination of electricity for nonpayment permitted by a provision of its general tariff filed with the Commission was a state action depriving her of property without due process

Appellee:  DISPOSITION OF THE COURT: 

Affirmed

RULE OF LAW:



A simple connection between the state and the private entity is not enough to implicate the state in the latter’s discriminatory conduct, there must be something more, i.e., a sufficiently close nexus between the State and the challenged action

HOLDING: 

PA’s regulation of a public utility does not constitute a state action

COURT’S REASONING:   

PA is not sufficiently connected with the challenged termination 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 14th Amendment If PA had granted Δ monopoly status this is not determinative of whether termination was a state action...