Cody v. Union Electric Co.

502 F. Supp. 1298, 1980 U.S. Dist. LEXIS 15418
CourtDistrict Court, E.D. Missouri
DecidedDecember 10, 1980
DocketNo. 74-736C(1)
StatusPublished

This text of 502 F. Supp. 1298 (Cody v. Union Electric Co.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cody v. Union Electric Co., 502 F. Supp. 1298, 1980 U.S. Dist. LEXIS 15418 (E.D. Mo. 1980).

Opinion

MEMORANDUM

WANGELIN, Chief Judge.

This matter is before the Court for a decision on the merits following a bench trial that involved the taking of evidence at various times over a period of thirteen (13) full days in late 1978 and early 1979. Plaintiffs bring this class action Civil Rights suit challenging defendant’s commercial security deposit policy and defendant’s credit practices and procedures, alleging violations of 42 U.S.C. § 1981 and the Thirteenth and Fourteenth Amendments.

After consideration of the testimony adduced at trial, the exhibits introduced in evidence, the briefs of the parties, and the applicable law, the Court hereby makes and enters the following findings of fact and conclusions of law. Any finding of fact equally applicable as a conclusion of law is hereby adopted as such and, conversely, any conclusion of law applicable as a finding of fact is adopted as such.

Findings of Fact

1. Defendant Union Electric Company is a Missouri public utility which provides electricity to both private and commercial customers. Before the commencement of service to a commercial customer, Union Electric Company requires all new commercial customers to pay a cash security deposit unless the customer can establish a satisfactory credit history with the company or otherwise demonstrate credit worthiness.

2. Union Electric’s commercial security deposit policy is authorized by the Rules and Regulations of the Missouri Public Service Commission — General Order No. 20, Rule 12. This Rule was originally filed as a part of the Company’s tariff on July 31, 1959, and refiled on July 12,1978; the Rule was most recently approved again by the Missouri Public Service Commission on July 19, 1978.

3. The challenged security deposit policy provides inter alia that Union Electric may at any time as a condition to furnishing or continuing service require any commercial customer to make a cash deposit or at the Company’s option furnish a personal guarantee, bond or bank letter of credit. The deposit or guarantee shall not exceed an estimated bill covering one billing period plus thirty (30) days. Any cash deposit held by the Company for six months or longer shall accrue simple interest at the rate of [1300]*1300six per cent (6%) per annum from the day the deposit was lodged with the utility. The deposit shall be retained by Union Electric as a surety until either the customer establishes, in the opinion of the company, satisfactory credit or the commercial customer’s account is closed at which time the Company shall refund to the customer the amount of the deposit as well as interest accrued, after subtracting any indebtedness of the customer to the Company.

4. Union Electric determines the amount of security deposit required before commencement of service by reviewing the record of electric usage at the particular business address, selecting the highest bill in the past twelve month period and doubling this amount. This is a proper approximation of the amount under guidelines set forth in Section VIII of the General Rules and Regulations of the Missouri Public Service Commission. If no prior record of the electric usage for the business is available, a Company sales representative estimates the annual revenue for the particular business account and Union Electric credit personnel use this estimated annual revenue figure to determine the probable amount of usage for two months to arrive at the deposit amount. There are also occasions when credit personnel determine that these general indications are not a valid measurement of electricity usage for that particular type of business. Such estimations are based upon the credit personnel’s general knowledge and experience in determining a business’s potential electricity usage.

5. Since at least 1959 Union Electric has required all of its commercial customers to pay a cash security deposit, calculated according to the guidelines approved by the Missouri Public Service Commission, unless the customer could establish a satisfactory business credit history with the Company or in some other manner establish a good credit rating. A customer’s prior untimely payment of bills or the forwarding of bad checks are among the factors which may indicate the quality of the customer’s credit risk at a new account he has opened. Similarly, a poor credit record influences when, if ever, a customer is entitled to a refund of all or part of his security deposit prior to the closing of an account.

6. The customer may petition the utility for a reassessment of the electric usage estimation if he feels that it is not an accurate computation. Such a request is readily received by the Company and the utility company may adjust the required deposit downward. However, the utility is the final arbiter of the accuracy of the deposit estimation.

7. If the utility is unable to make an accurate estimation of the electricity usage for that particular business address, it will charge a minimum of $50.00 as a security deposit. This assessment is made when the Company is unable to determine the previous usage history of the meter at the particular business address.

8. The security deposit charge is a reasonable economic measure employed solely to ensure a minimal number of uncollectible bills. This policy has saved Union Electric $48,000 in a fiscal year dating from September, 1977 to September, 1978.

9. The commercial security deposit is reviewed after three years for a determination of the worthiness of a refund. If the credit history of the business is satisfactory the deposit is then automatically refunded with interest. Prior to June 29, 1977, refunds of deposits were determined by an individual review of the business customer’s account history.

10. Credit department personnel who make a decision on the amount of deposit to be required by a business take into account whether the applicant has ever had a commercial account with the Company and the address of that account. If a prior commercial account with the Company can be identified this information is reviewed to make an assessment of this applicant’s prior payment history. Such factors as prior delinquent or nonexistent payment histories play a significant role in the credit department’s assessment of the desirability of a deposit and its amount.

11. New service applications are taken by adjusters of the customer business de[1301]*1301partment over the telephone or at the customer service office. These adjusters make the background determination of whether an applicant has ever had a commercial account with the Company and, if so, the address of that account.

12. Both the credit department and the customer service office are staffed with black as well as white employees. Three of the nine credit persons employed by Union Electric are charged with the responsibility of implementing the deposit policy. One of four senior credit persons is black.

13. The racial identity of the potential customer is not noted on the Company’s records. The racial identity of the potential customer is in no way a factor in the decision of Union Electric to demand a security deposit nor is it a factor in the determination of the amount of deposit requested. This factual determination is evidenced by testimony of a black woman who is the Company’s supervisor of the customer service for the 12th Street office in St.

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Bluebook (online)
502 F. Supp. 1298, 1980 U.S. Dist. LEXIS 15418, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cody-v-union-electric-co-moed-1980.