Jackson v. Metropolitan Edison Co.
419 U.S. 345 (1974)
Jackson didn't pay her
electric bill. The electric company (Metropolitan Edison) turned off her
Jackson sued, claiming a
denial of due process.
Jackson claimed that the
delinquency was in error, and the 14th Amendment said that she could not be deprived of
utility service without adequate notice and a hearing before an impartial
Basically, Jackson was claiming
that utilities were a governmental function performed by a private
entity, and thus subject to constitutional protections.
Metropolitan Edison claimed
that they were a private entity and were not subject to the due
process requirements of the 14th
Amendment based on the State Action Doctrine.
The US Supreme Court found
that the 14th Amendment'sdue process requirement did not apply to private entities.
argued that the partial monopoly granted by Pennsylvania, the extensive
state regulation, and the essential nature of utility operations as
evidence of the State character of the utility's actions.
However, the US Supreme
Court found that Pennsylvania was not sufficiently connected with
Metropolitan Edison's action in terminating Jackson's service so as to
make respondent's conduct in so doing attributable to the State for
purposes of the 14th Amendment.
This case shows the limits of
the Public Function Exception to
the State Action Doctrine.
The Public Function
Exception says that when a private
entity is engaged in activity that has been traditionally, exclusively
done by the government, then they are bound by the Constitution, even
though the State Action Doctrine generally limits the reach of the Constitution to actions taken
by governmental agencies.
In this case the Court
found that even though utilities are monopolies created in the public
interest, their activity is not 'governmental' enough to meet the Public