Question

Review the following court case:

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


Rehnquist, J. Respondent Metropolitan Edison Co. is a privately owned and operated Pennsylvania corporation which holds a certificate of public convenience issued by the Pennsylvania Public Utility Commission empowering it to deliver electricity to a service area which includes the city of York, PA. As a condition of holding its certificate, it is subject to extensive regulation by the Commission. Under a provision of its general tariff filed with the Commission, it has the right to discontinue service to any customer on reasonable notice of nonpayment of bills. Petitioner Catherine Jackson is a resident of York, who has received electricity in the past from respondent. Until September 1970, petitioner received electric service to her home in York under an account with respondent in her own name. When her account was terminated because of asserted delinquency in payments due for service, a new account with respondent was opened in the name of one James Dodson, another occupant of the residence, and service to the residence was resumed. ... In August 1971, Dodson left the residence. Service continued thereafter but concededly no payments were made. Petitioner states that no bills were received during this period. On October 7, 1971, employees of Metropolitan came to the residence and inquired as to Dodson's present address. Petitioner stated that it was unknown to her. On the following day, another employee visited the residence and informed petitioner that the meter had been tampered with so as not to register amounts used. She disclaimed knowledge of this and requested that the service account for her home be shifted from Dodson's name to that one of Robert Jackson, later identified as her 12-year-old son. Four days later on October 11, 1971, without further notice to petitioner, Metropolitan employees disconnected her service. Petitioner then filed suit against Metropolitan in the United States District Court for the Middle District of Pennsylvania under the Civil Rights Act of 1871,42U.S.C. $ 1983, seeking damages for the termination and an injunction requiring Metropolitan to continue providing power to her residence until she had been afforded notice, a hearing, and an opportunity to pay any amounts found due. She urged that... Metropolitan's termination of her service for alleged nonpayment... constituted "state action" depriving her of property in violation of the Fourteenth Amendment's guarantee of due process of law. The District Court granted Metropolitan's motion to dismiss petitioner's complaint on the ground that the termination did not constitute state action and hence was not subject to judicial scrutiny under the Fourteenth Amendment. On appeal, the United States Court of Appeals for the Third Circuit affirmed, also finding an absence of state action. We granted certiorari to review this judgment.

1. What are the facts of this case? What is the issue?

2. In what court was it decided, and how did it get to that court?

3. What did the court below decide, and why? What did this court decide, and why?

4. What does it mean to be "affected with the public interest"?

5. What is the significance of the Fourteenth Amendment to the U.S. Constitution in this case? What does one have to prove to establish a "due process" claim under the Fourteenth Amendment?

6. Why is the Burton case important for this decision? What was the key factor in Burton, and why was the result in that case different than in Jackson?

7. What would have been the implications of the opposite result in this case (for hospitals, for example)?

Answer 1

HOMEWORKLIB POLICY requires first 4 parts to be answered. Solving as many as possible in the given time.

1. The facts of the case-

• It is a case between one Mrs. Catherine Jackson and Metropolitan Edison Co, filed by Mrs. Jackson.
• Jackson stayed in an apartment which had an electricity connection in the name of one James Dodson. Due to delinquency the and the fact that Mrs. Jackson could not tell where Mr. Dodson lived, the connection was cut.
• Mrs. Jackson filed the case stating that she should get damages and injunction against the termination as the termination was a 'state action' and she was not accorded due process of law, as stated in the Civil Rights Act of 1871.

The issue here is to decide whether the action by Metropolitan Edison Co constituted state action, since only state action must be accorded due process in the Civil Rights act of 1871.

2. It was decided in the United States Court for appeals of Third Circuit. It got there because a review petition was filed by Ms. Jackson against the judgement given by the district court.

3. The district court dismissed the petitioner's complaint since it decided that termination by Metropolitan did not constitute state action. This court agreed with the lower court and dismissed the review petition.

4. Affected with the public interest means that though the business may be private, it provides services that are of great use to the public and hence the public has a stake in it. It is used in the case of services which, while owned privately, are providing essential services to the general public.

5. Fourteenth amendment contains a due process clause and hence it is important in this case. The clause states that 'nor shall any State deprive any person of life, liberty, or property, without due process of law.' It means that state can't deprive a person of life, liberty or property without having gone through the required process under law. It is important in this case because Ms.Jackson is claiming that in terminating the connection, Metropolitan did not accord her the due process of law.

One has to establish that the state was depriving him/her of life, freedom, property or other such basic human rights to establish 'due process'.