Jackson v. Metropolitan Edison Co., 419 U.S. 345 (U.S. 1974)
Facts
The plaintiff was a woman from California that brought a federal civil rights action against Metropolitan Edison Co, a private company subject to extensive state regulation because it had a certificate from the state allowing it to provide electricity to a specified area. The plaintiff brought this action after the Respondent terminated her electrical service without notice for alleged non-payment. She claimed that respondent constituted state action and without notice she had received no procedural due process.
Procedural Posture
The lower Court dismissed the plaintiff’s claim. She appealed and the case made it to the Supreme Court where judgment of the lower state courts affirmed.
Holding
The United States Supreme Court held that this was not state action. Just because there was an approval by a state utility commission of a request made by a regulated utility does not constitute state action.
Discussion
As indicated by the court, the public function doctrine, which includes delegation, should not be read broadly. This utility company was not a state actor simply because the government authorized and approved the electric company to provide public service.
Likely Future Importance
The public function doctrine is limited to instances when private actors exercise power traditionally exclusively reserved for the government. State regulation alone is not state action.