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Mediaone Group, Incorporated Mediaone of Virginia, Incorporated At&t Corporation v. County of Henrico, Virginia, Bell Atlantic Corporation Bell Atlantic-Virginia, Incorporated Bell Atlantic Internet Solutions, Incorporated, Intervenors/defendants, and Gte Intelligent Network Services, Incorporated, D/B/A gte.net, Intervenor-Appellant. Virginia Citizens Consumer Council Consumer Federation of America Center for Media Education District of Columbia City of Tacoma, Washington Montgomery County, Maryland U.S. Conference of Mayors National League of Cities National Association of Counties National Association of Telecommunications Officers and Advisors Virginia Association of Telecommunications Officers and Advisors Texas Association of Telecommunications Officers and Advisors Minnesota Association of Community Telecommunications Administrators Opennet Coalition Hands Off the Internet Federal Communications Commission National Cable Television Association Virginia Telecommunications Association West Virginia Telec

Citation: 257 F.3d 356Docket: 00-1680

Court: Court of Appeals for the Fourth Circuit; July 16, 2001; Federal Appellate Court

Narrative Opinion Summary

In a case involving AT&T Corporation, MediaOne Group, Inc., and MediaOne of Virginia, Inc. against the County of Henrico, Virginia, the core legal issue concerned the preemption of local telecommunications regulations by federal law. The plaintiffs challenged the County's requirement for open access to MediaOne's cable modem platform, arguing it was preempted by the Communications Act of 1934, as amended by the Telecommunications Act of 1996. The United States District Court for the Eastern District of Virginia ruled in favor of the plaintiffs, granting summary judgment on the basis that the County's condition violated multiple sections of the Communications Act by imposing inconsistent requirements on telecommunications services. On appeal, the Fourth Circuit Court affirmed the district court's decision, emphasizing the preemptive effect of federal law over local regulations and rejecting the state law arguments as not providing an independent basis for decision. The court also noted the ongoing FCC proceedings regarding the classification of cable modem services, deferring to the agency's expertise. The decision underscored the primacy of federal regulatory frameworks in governing telecommunications infrastructure and services, affirming that Henrico County's ordinance was invalid under both federal preemption principles and Virginia law.

Legal Issues Addressed

Cable Service Classification under the Communications Act

Application: The classification of MediaOne's Road Runner service as a cable service or telecommunications service was debated, impacting the regulatory framework applicable to the service.

Reasoning: The County asserts it is a 'cable service,' which would allow local regulation of Internet access over cable lines, while Verizon argues it should be classified as a 'telecommunications service.'

Federal Preemption under the Communications Act

Application: The court found that local regulations imposing open access conditions on cable operators are preempted by federal law, specifically the Communications Act.

Reasoning: The district court ruled in favor of AT&T and MediaOne, determining that the open access condition was preempted by various sections of the Communications Act.

Judicial Deference to Federal Agency Expertise

Application: The court deferred to the FCC's ongoing proceedings regarding the classification of cable modem services, recognizing the complexity and need for expert agency determination.

Reasoning: The classification of cable modem services like Road Runner is complex and under review by the FCC, which has initiated proceedings to explore whether such services should be classified as cable, telecommunications, or information services.

Regulatory Authority of Local Governments

Application: Henrico County's requirement for open access to MediaOne's cable modem platform exceeded its regulatory authority under Virginia law, as it conflicted with federal preemption principles.

Reasoning: Virginia Code § 15.2-2108(E) prohibits localities from regulating cable television systems in ways that conflict with state or federal laws governing such operations.

State Law Consistency with Federal Law

Application: Virginia law prohibits local regulations that conflict with federal statutes, aligning with the Communications Act to preempt county-imposed open access requirements.

Reasoning: The Virginia cable statute prohibits any local cable regulation that conflicts with federal law, specifically the Communications Act.