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Jackson v. Metropolitan Edison Co

Law Dictionary
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Featuring Black's Law Dictionary 2nd Ed.
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Constitutional Law Keyed to Sullivan

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Bloomberg Law

Citation. 419 U.S. 345,95 S. Ct. 449,42 L. Ed. 2d 477,1974 U.S.

Brief Fact Summary. The Respondent, Metropolitan Edison Co. (Respondent), a private utilities company was held not to be a state actor and therefore, the Petitioner, Catherine Jackson (Petitioner), was not entitled to continuous electrical service nor did the company’s termination of electrical services constitute a deprivation of her property without procedural due process.

Synopsis of Rule of Law. A private company that does not have specific authorization by the state to act, is not acting on behalf of the state.


Facts. The Petitioner brought a federal civil rights action under 42 U.S.C. Section:1983 against the Respondent, a private company subject to extensive state regulation because it held a certificate public convenience from the Pennsylvania Public Utilities Commission (PPUC) empowering it to deliver electricity to a specific area. Petitioner sought damages and injunctive relief against Respondent for terminating her electrical service for alleged nonpayment, claiming she had not been afforded notice, hearing and an opportunity to pay amount due. She claimed that under state law, she was entitled to reasonably continuous electrical service and that the Respondent’s termination constituted state action without procedural due process. The lower courts dismissed her claim.

Issue. Whether Respondent’s termination of Petitioner’s electricity constituted state action?

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