Education. In Peoria and Parsons, the plaintiffs made the eligibility for federal aid argument and added the argument that state action existed because the accreditation agency was incorporated, and thus a creature of state law. The arguments asserted in those cases were easily disposed of under traditional state action doctrine. Collateral consequences of eligibility for federal aid is not enough for state action under Blum v. Yaretsky, U.S. 991, 102 S.Ct. 2777, 73 L.Ed.2d 534 (1982); a company is not a state actor merely because it is itself regulated, see Jackson, 419 U.S. at 352-55, 95 S.Ct. at 454-55; and a corporate charter cannot create “state action” because such a rule would transform nearly every business entity into a state actor, cf. Burton, 365 U.S. at 726, 81 S.Ct. at 862 (<HOLDING>). In this case, by contrast, McKeesport can
recognizing the need to avoid a rule that creates universal application of state actor status holding that amtrak was a state actor recognizing district court application of the same rule holding that a state agency created under state law was a state actor holding that fraud creates an exception to the rule