Campanelli v. AT&T Wireless Services, Inc.

“[A]n entity may be characterized as a public utility if the nature of its operation is a matter of public concern.” Marano v. Gibbs (1989), 45 Ohio St.3d 310, 311, 544 N.E.2d 635, 637. To determine whether the nature of an entity’s operation is a matter of public concern, the majority states that three principal factors must be considered: “lack of competition in the local marketplace, the good or service provided, and the existence of regulation by government authority.” See A & B Refuse Disposers, Inc. v. Ravenna Twp. Bd. of Trustees (1992), 64 Ohio St.3d 385, 388, 596 N.E.2d 423, 426. The…