Jackson v. Metropolitan Edison Co.

Metropolitan Edison Co. (Edison) (defendant) was a privately owned and operated electricity company that was authorized by the Pennsylvania Public Utility Commission (commission) to deliver electricity to York, Pennsylvania, and surrounding areas. It was subject to extensive regulation by the commission and was granted approval by the commission to discontinue service to any customer on reasonable nonpayment of bills. Catherine Jackson (plaintiff) was a resident of York and customer of Edison. She defaulted on her bill payments and had her service disconnected but convinced Edison to reinstate it under the name of James Dodson, another resident in her home. However, when Dodson moved out of the home and Jackson continued to default on the payments, Edison visited the premises and attempted to collect payment. Jackson requested that the service be reinstated under another name, which Edison later discovered was that of her 12-year-old son. Edison disconnected Jackson’s service four days later with no other notice. Jackson brought suit in district court alleging that under the Due Process Clause of the Fourteenth Amendment, she could not be deprived of electricity service without adequate notice and a hearing before an impartial body. The district court dismissed the case because it found no state action present, and the court of appeals affirmed. The United States Supreme Court granted certiorari.