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Case Basics
Docket No. 
Catherine Jackson
Metropolitan Edison Co.
(argued the cause for the petitioner)
(argued the cause for the respondent)
Facts of the Case 

Catherine Jackson had received electricity from Metropolitan Edison at her home. Her service was terminated in September 1970 due to a lack of payment. Jackson opened another account under the name of another resident, James Dodson. Metropolitan Edison investigated her residence on October 6, 1971 and service was again terminated without notice on October 11. Jackson sued in federal district court under 42 U.S.C. Section 1983. She sought damages for the termination and an injunction to continue her service. The court dismissed her suit. The United States Court of Appeals for the Third Circuit affirmed the dismissal.


Did Metropolitan Edison's termination of Jackson's electrical service qualify as "state action" under the Fourteenth Amendment?

Decision: 6 votes for Metropolitan Edison Co., 3 vote(s) against
Legal provision: Due Process

No. In a 6-3 opinion delivered by Justice William H. Rehnquist, the court affirmed the Third Circuit and held that Metropolitan Edison's termination of Jackson's service did not qualify as state action. Rehnquist reiterated that private actions are "immune from the restrictions of the Fourteenth Amendment." The Court acknowledged that Metropolitan Edison was heavily regulated by the Pennsylvania Public Utility Commission, but this regulation did not make Metropolitan Edison part of the state. Additionally, the Court cited Nebbia v. New York in declining to rule on whether all actions by businesses that provided essential public services qualified as state action.

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JACKSON v. METROPOLITAN EDISON CO.. The Oyez Project at IIT Chicago-Kent College of Law. 03 June 2015. <http://www.oyez.org/cases/1970-1979/1974/1974_73_5845>.
JACKSON v. METROPOLITAN EDISON CO., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1970-1979/1974/1974_73_5845 (last visited June 3, 2015).
"JACKSON v. METROPOLITAN EDISON CO.," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 3, 2015, http://www.oyez.org/cases/1970-1979/1974/1974_73_5845.