## Facts

- Catherine Jackson was a residential electric customer of Metropolitan Edison Company, a privately owned utility in Pennsylvania operating under a state certificate and extensive public-utility regulation.
- The utility’s filed tariff, approved by the Pennsylvania Public Utility Commission (PUC), permitted service discontinuance for nonpayment upon reasonable notice.
- Jackson’s service was discontinued for nonpayment and later restored under another resident’s name; after additional nonpayment, the utility investigated and found a tampered meter and an attempted account transfer into Jackson’s 12-year-old son’s name.
- Metropolitan Edison disconnected service without further notice.
- Jackson sued under 42 U.S.C. § 1983 for damages and injunctive relief, alleging a property interest in continued electric service and deprivation of due process under the Fourteenth Amendment.

## Issues

1. Whether a privately owned electric utility’s termination of service, taken under a PUC-approved tariff and within a state-regulated monopoly framework, is attributable to the State as “state action” for Fourteenth Amendment and § 1983 purposes.
2. Whether state approval or authorization of a utility’s termination practice, without ordering or coercing the specific termination, creates a sufficiently close nexus between the State and the challenged conduct.
3. Whether providing electric service is a function traditionally and exclusively reserved to the State such that the utility’s conduct constitutes state action under the public function doctrine.

## Decision

- The Supreme Court affirmed dismissal of the § 1983 action.
- The Court held the service termination was not “state action” because Pennsylvania was not sufficiently connected to the specific disconnection decision to make it fairly attributable to the State.
- Extensive regulation and partial monopoly status did not, without more, convert the utility’s actions into state conduct.
- PUC approval of the termination tariff did not amount to state responsibility because the State did not order, compel, or significantly encourage the challenged termination practice.
- Operating an electric utility was not a function traditionally the exclusive prerogative of the State, so the public function theory did not apply.

## Legal Principles

- The Fourteenth Amendment constrains state conduct, not merely private conduct; a private party’s act is subject to constitutional limits only when there is a sufficiently close nexus between the State and the challenged action.
- Extensive state regulation and state-conferred monopoly status, standing alone, do not make a regulated private entity’s decisions attributable to the State.
- State authorization or regulatory approval of a privately initiated practice does not constitute state action absent meaningful state involvement, such as coercion, significant encouragement, or ordering of the practice.
- The public function doctrine applies only when the private entity performs a function traditionally and exclusively reserved to the State; providing electric service is not such an exclusive function.

## Conclusion

Because the utility’s decision to terminate service for nonpayment, though permitted by a PUC-approved tariff within a heavily regulated monopoly setting, was not fairly attributable to Pennsylvania, the challenged termination was not state action and could not support a Fourteenth Amendment due process claim under § 1983.


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