In the Matter of the Alleged Failure of Altice USA, Inc., to Comply With Certain Provisions of the New Jersey Cable Television Act and the New Jersey Administrative Code

CourtSupreme Court of New Jersey
DecidedApril 3, 2023
DocketA-2/3-22
StatusPublished

This text of In the Matter of the Alleged Failure of Altice USA, Inc., to Comply With Certain Provisions of the New Jersey Cable Television Act and the New Jersey Administrative Code (In the Matter of the Alleged Failure of Altice USA, Inc., to Comply With Certain Provisions of the New Jersey Cable Television Act and the New Jersey Administrative Code) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Alleged Failure of Altice USA, Inc., to Comply With Certain Provisions of the New Jersey Cable Television Act and the New Jersey Administrative Code, (N.J. 2023).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

IMO the Alleged Failure of Altice USA, Inc., to Comply with Certain Provisions of the New Jersey Cable Television Act & the New Jersey Administrative Code (A-2/3-22) (086408)

Argued January 17, 2023 -- Decided April 3, 2023

FASCIALE, J., writing for a unanimous Court.

In this appeal, Altice USA, Inc. (Altice) challenges N.J.A.C. 14:18-3.8, a regulation requiring cable companies to refund or not charge customers who cancel cable service before the end of a billing cycle for cable service after the date of cancellation. Altice argues that N.J.A.C. 14:18-38’s proration requirement effectively regulates its “rates for the provision of cable service” and is therefore expressly preempted by 47 U.S.C. § 543(a)(1), a section of the federal Cable Communications Policy Act of 1984 (Cable Act). Assuming it is correct, Altice maintains that accordingly, once its customers sign up for a monthly plan, they must pay for a full final month of cable service even if they terminate service before the month ends. The Board of Public Utilities (the BPU) and Division of Rate Counsel disagree and contend this consumer protection regulation is a valid exercise of the State’s police power, which they argue the Cable Act explicitly authorizes. Alternatively, Altice asserts that even if the consumer protection regulation is not preempted, the BPU expressly waived compliance with that requirement.

In 2011, Cablevision Systems Corporation (Cablevision), Altice’s predecessor, petitioned the BPU for relief from various rules. BPU granted Cablevision’s request for relief from compliance with certain rules, expressly conditioned on Cablevision’s continuing to “prorate its bills pursuant to the requirements” of state law. As part of its request for relief, Cablevision submitted to the BPU sample customer bills that evidenced intent to continue prorating bills under N.J.A.C. 14:18-3.8.

In 2015, Altice petitioned the BPU for approval of its merger with Cablevision Cable Entities. In May 2016, the BPU issued an Order approving the merger with the expectation that Altice would comply with N.J.A.C. 14:18-3.8.

Altice then began selling cable service to New Jersey residents. On its own, Altice selected a monthly rate and billed customers at that rate. Initially, Altice 1 prorated bills for customers who cancelled service mid-month. But that changed in October 2016. Without notifying the BPU, Altice altered its practice and stopped prorating bills for customers who cancelled service before the end of a month. Hundreds of customers complained to the BPU about not receiving a refund for cancelled service, which led to this enforcement action.

In 2019, finding that Altice failed to prorate customer bills in violation of N.J.A.C. 14:18-3.8, the 2011 Relief Order, and the 2016 Merger Order, the BPU ordered Altice to cease and desist from failing to prorate monthly bills; refund affected customers; remit a one-time contribution to the Altice Advantage Internet program; and audit billing records.

Altice appealed the BPU’s cease-and-desist order to the Appellate Division. Focusing solely on preemption grounds, the appellate court invalidated the order. The Court granted certification. 252 N.J. 60 (2022).

HELD: Section 543(a)(1) of the Cable Act does not preempt the proration requirement in N.J.A.C. 14:18-3.8. The regulation does not regulate “rates for the provision of cable service,” but rather prevents cable companies from charging for cable service that customers have cancelled. The regulation does not set the “rate” that companies can charge. It simply protects cable users from paying for service they no longer want. Furthermore, contrary to Altice’s alternative argument, neither Altice nor its predecessor sought or received a BPU waiver from prorating cable bills.

1. The Supremacy Clause of the United States Constitution provides that federal law “shall be the supreme Law of the Land,” notwithstanding any state law to the contrary. U.S. Const. art. VI, cl. 2. Here, Altice argues that Section 543(a)(1) expressly preempts N.J.A.C. 14:18-3.8. Section 543 of the Cable Act prohibits rate regulation in competitive cable system markets. It does not expressly prohibit proration of bills. Instead, Section 543(a)(1) states in part that “[n]o Federal agency or State may regulate the rates for the provision of cable service except to the extent provided under this section.” (emphasis added). Section 543(a)(2) explains that “[i]f the [Federal Communications] Commission [(FCC)] finds that a cable system is subject to effective competition, the rates for the provision of cable service by such system shall not be subject to regulation by the Commission or by a State or franchising authority under this section.” N.J.A.C. 14:18-3.8, in turn, has two relevant subsections. Under subsection (a), “Bills for cable television service shall be rendered monthly, bi-monthly, quarterly, semi-annually or annually and shall be prorated upon establishment and termination of service. In unusual credit situations, bills may be rendered at shorter intervals.” Subsection (c) provides in part that “[i]nitial and final bills shall be prorated as of the date of the initial establishment and final termination of service.” Finally, another section of the Cable Act 2 explicitly preserves a state’s police power to enact and enforce consumer protection laws. See 47 U.S.C. § 552(d)(1). Combining the preemption clause in Section 543(a)(1) and the savings clause of Section 552(d)(1), so long as a consumer- protective measure like N.J.A.C. 14:18-3.8 does not “regulate the rates for the provision of cable service,” it is not specifically preempted. (pp. 10-14)

2. N.J.A.C. 14:18-3.8’s proration regulation does not regulate Altice’s cable “rates,” let alone control “rates for the provision of cable service.” The Court reviews the definitions of relevant terms used in the statute. Applying the term’s ordinary and plain meaning, a “rate” is not only the price or the unit of utility service sold; it is the ratio of price to unit. Here, the challenged regulation does not even indirectly affect the actual rate Altice charges; rather, it prohibits applying the service rate to a period after a customer cancels cable service. Altice sets its own competitive marketplace “rate.” N.J.A.C. 14:18-3.8’s proration requirement does not “regulate” that rate -- that is, it does not fix, establish, adjust, or control Altice’s rate. The regulation merely uses the rate that the cable provider sets to enforce a price proportional to the quantity of service provided. The Court disagrees with the notion that proration impliedly creates a new daily “rate” for the month of termination. Further, Section 543(a)(1) preempts only the regulation of “rates for the provision of cable service.” (emphasis added). The proration requirement applies only after “final termination of service,” N.J.A.C. 14:18-3.8(c), when the “provision of cable service” has ended. The Court reviews case law and FCC determinations, which support the conclusion N.J.A.C. 14:18-3.8 is not preempted by federal law. The Court notes Altice cannot by the terms of its contract interfere with the consumer-protective regulation’s proration requirement. (pp. 14-24)

3. The Court disagrees that the BPU excused Altice from complying with N.J.A.C. 14:18-3.8’s proration requirement.

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In the Matter of the Alleged Failure of Altice USA, Inc., to Comply With Certain Provisions of the New Jersey Cable Television Act and the New Jersey Administrative Code, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-alleged-failure-of-altice-usa-inc-to-comply-with-nj-2023.