Crowell v. Benson
Crowell v. Benson, 285 U.S. 22 (1932), is the first United States Supreme Court decision that approved the adjudication of private rights by an administrative agency, not an Article III court. The Court held that the United States Employees' Compensation Commission satisfied Fifth Amendment Due Process and the requirements of Article III with its court-like procedures and because it invests the final power of decision in Article III courts.
| Crowell v. Benson | |
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| Argued October 20–21, 1931 Decided February 23, 1932 | |
| Full case name | Crowell, Deputy Commissioner v. Benson |
| Citations | 285 U.S. 22 (more) 52 S. Ct. 285; 76 L. Ed. 598; 1932 U.S. LEXIS 773 |
| Court membership | |
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| Case opinions | |
| Majority | Hughes, joined by Holmes, Devanter, McReynolds, Sutherland, Butler |
| Dissent | Brandeis, joined by Stone, Roberts |
Background
The Deputy Commissioner of the United States Employees' Compensation Commission found that Knudsen was injured while in Benson's employ and while performing services on the navigable waters of the United States. He made an award to Knudsen under the Longshoremen's and Harbor Workers' Compensation Act. Benson brought suit in the District Court to enjoin enforcement of the award.
Decision of the Court
Justice Hughes writing for the court reaffirmed the opinion of the lower courts. He stated the main question in the case to be "whether Congress may substitute for constitutional courts, in which the judicial power of the United States is vested, an administrative agency -- in this instance a single deputy commissioner -- for the final determination of the facts upon which the enforcement of the constitutional rights of the citizen depend."[1] Another issue before the Court was whether the determinations of fact (that the injury occurred on navigable waters and that a master-servant relationship existed) were "fundamental or 'jurisdictional' in the sense that their existence is a condition precedent to the operation of the statutory scheme". The Court held that the Act reserved full power to pass on questions of law to admiralty courts, and if the court found it necessary to set aside an order as not in accordance with the law, the Act did not preclude it from making its own determination of jurisdictional or fundamental facts. It was consistent with due process for Congress to allow findings on questions of fact (apart from constitutional rights) to be final as determined by the Commissioner if supported by the evidence.[2]
In short, in cases brought to enforce constitutional rights, the judicial power extends to independent determination of all questions - both fact and law. The Court construed the Act to allow federal courts to determine the existence of fundamental or jurisdictional facts in order to avoid a potential Article III problem.
Dissenting Opinion
Justice Brandeis argued that "[t]o permit a contest de novo in the district court of an issue tried, or triable, before the deputy commission will . . . gravely hamper the effective administration" of an Act. He felt that the Court had no reason to make exceptions for issues of constitutional rights. Nothing in the Constitution prevented Congress from assigning the exclusive power to collect evidence and make factual determinations. Justice Brandeis noted that the whole purpose of administrative tribunals was to withdraw from the courts certain cases that would be more effectively handled by a special and expert tribunal.[3]
External links
- Text of Crowell v. Benson, 285 U.S. 22 (1932) is available from: Findlaw Justia Library of Congress