Jackson v. Metropolitan Edison Co.

Metropolitan Edison (defendant) was a private, state-regulated electric utility authorized to serve York, Pennsylvania, with Public Utility Commission approval to disconnect nonpaying customers. Jackson (plaintiff), a York customer, defaulted and had service disconnected, got it reinstated under another resident's name, defaulted again, and had it reinstated once more under a name Edison later discovered was her twelve-year-old son's. Edison then disconnected her service with no further notice. Jackson sued, claiming due process required notice and a hearing before termination. The district court found no state action and dismissed; the court of appeals affirmed.