Wednesday, November 6, 2013

Jackson v. Metropolitan Edison Co. case brief

Jackson v. Metropolitan Edison Co. case brief summary
419 U.S. 345 (1974)

CASE SYNOPSIS
Petitioner consumer sought review by certiorari of a decision of the United States Court of Appeals for the Third Circuit affirming the dismissal of her 42 U.S.C.S. § 1983 action against respondent utility company. Petitioner argued the court erred in finding that the termination of her electric service did not constitute state action and hence was not subject to judicial scrutiny under the Fourteenth Amendment.

CASE FACTS
After respondent utility company terminated her electricity for non-payment, petitioner consumer filed suit under 42 U.S.C.S. § 1983, seeking damages for the termination and an injunction requiring the utility company to continue providing service until she was afforded notice, a hearing, and an opportunity to pay any amounts found due. Petitioner urged that the termination of her service, allowed by a provision of the utility company's general tariff filed with the state public utility commission, constituted "state action" depriving her of property in violation of the Fourteenth Amendment's guarantee of due process of law.

DISCUSSION
  • The district court found that the termination did not constitute state action and was not subject to judicial scrutiny under the Fourteenth Amendment, and the appeals court affirmed. 
  • The Court held that the state was not sufficiently connected with the utility company's action in terminating petitioner's service to make its conduct in so doing attributable to the state for purposes of the Fourteenth Amendment. 
  • The Court lacked jurisdiction to decide whether petitioner's claim to continued service was "property" for purposes of that Amendment.

CONCLUSION

The Court affirmed the decision affirming the dismissal of petitioner's civil rights action against respondent utility company because the termination of her electric service did not constitute state action. The Court ruled that the state's approval of the utility company's business practices did not transmute the termination into state action.

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