Jackson v. Metropolitan Edison Co
Jackson v. Metropolitan Edison Co. is a significant case concerning the intersection of private utility regulation and due process rights. The case arose when a Pennsylvania resident alleged that Metropolitan Edison Co., a regulated utility company, did not provide adequate notice or a public hearing before terminating her electrical service. The resident contended that the company's status as a heavily regulated partial monopoly imposed certain obligations under the due process clause. However, the Supreme Court ruled that the due process protections apply only to state actions and not to private entities like the utility company. This ruling clarified the limits of constitutional protections in the context of private service providers and has influenced subsequent legislative measures regarding utility regulation. Although the case established a precedent, it has been addressed and modified by later laws. The case continues to be relevant in discussions about consumer rights, utility regulation, and due process in the context of private companies.
Jackson v. Metropolitan Edison Co.
Date: December 23, 1974
Citation: 419 U.S. 345
Issue: Procedural due process
Significance: The Supreme Court, in a ruling involving a utility company, set a standard for determining when actions by private entities were public enough to fall under the constitutional limitations applied to the government.
A Pennsylvania resident claimed that Metropolitan Edison Co., a private utility company, failed to provide adequate notice and a public hearing before terminating her electrical service, thus violating her due process rights. The resident argued that the utility was an extensively regulated partial monopoly, but the Supreme Court did not find the company to be sufficiently public to merit the burden of the constitutional limits placed on governments. The due process clause, the Court argued, applies only to state actions, not those of a private entity such as the utility. This ruling was never overturned, but it was limited by a number of legislative enactments.
![First Energy Building and Akron Centre Plaza in Akron, Ohio. The Metropolitan Edison Company is now a unit of FirstEnergy. By DangApricot (Own work) [CC-BY-SA-3.0 (http://creativecommons.org/licenses/by-sa/3.0) or GFDL (http://www.gnu.org/copyleft/fdl.html)], via Wikimedia Commons 95329948-92190.jpg](https://imageserver.ebscohost.com/img/embimages/ers/sp/embedded/95329948-92190.jpg?ephost1=dGJyMNHX8kSepq84xNvgOLCmsE2epq5Srqa4SK6WxWXS)
