Jackson v. Metropolitan Edison Co was one of the cases that involved interpretation of the law as far as state involvement in public utilities is concerned. In this case, the petitioner was Ms Jackson who had sued Metropolitan Edison Co. (defendant) for discontinued provision of electricity supply. On the other hand, the defendant, Metropolitan Edison Co. had discontinued supply of electricity services to Ms Jackson on ground that there was continued failure to settle bills in time and the meter had been tampered with.
Ms Jackson had continued to receive electricity supply services from Metropolitan Edison Co. under her own name until September 1970. Due to continued failure to settle electricity bills, electricity supply had been discontinued in her home. However, a new account was opened under the name James Dodson who was then residing at the residence. This was for a short period of time as Mr. Dodson left the apartment in August 1971 and electricity supply services were continued until there were not payments of electricity bill. On inquiry, the petitioner claimed that she had not received electricity bills for the time that the bills had not been settled. To ascertain her claims, Metropolitan Edison Co sent is employees on October 7th and they found out that the meter had been tampered with. However, Ms Jackson denied that she had any knowledge about the tampering of the meter. She further advised that electricity services to the residence to be transferred to Robert Jackson, who was later identified as her 12 years old son.
On October 11th, electricity services were terminated without any further notice.
Ms Jackson went to court on ground that electricity service supply to her residence had been cut off without being given due process of law as provided in the 14th Amendments. She argued that since Metropolitan Edison Co was highly regulated by the government, this amounted to a state action. The defendant however argued that the company had the right to discontinue services to any customer on reasonable notice because of failure to settle service bills. The main contention in the case was to prove whether the action of the company amounted to state action and whether her rights had been violated.
Outcome of the case
The court circuit affirmed the decision of dismissing petitioner civil rights action against the utility company on the ground that termination of electricity supply to her residence did not in any way constitute state action. This was supported by the fact that state approval and regulation of a utility company’s business practices does not transmute the termination to a state action.
Legal principles involved
The main principle that was applied in the case was the 14th Amendment, the Due Process clause. According to section 1 of the 14th Amendment, “[N]or shall any state deprive any person of life, liberty, or property, without due process of law, nor deny to any person within its jurisdiction the equal protection of the laws”. Herein this case, the plaintiff claimed the action of the utility company amounted to state action.
The principles highlighted in this case are applicable today in different ways. It has become common for most customers to enjoy services of most companies without paying bills. The most important application of this case is however the aspect of delineating state action from the actions of private businesses that operate independent of the state but highly regulated by the state and civil suits that may follow from their dealing with customers.
I. Facts of the case
- Plaintiff (Petitioner) in the case was Ms Jackson who had sued Metropolitan Edison Co. for termination of electricity supply terming it unlawful since it violated her rights under 14th Amendments
- Plaintiff argued that the action of the utility company amounted to state action which did not follow due process
- Defendant in the case was Metropolitan Edison Co. arguing that the company had the right to any customer on reasonable notice for failure of payment of bills
II. Outcome of the case
- The court ruled that the action of the utility company did not in any way amount to state action because the utility company was acting in its own capacity
- Civil rights of the plaintiff were therefore not violated.
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