Crowell v. Benson
| What is a federal administrative adjudicator? Federal administrative adjudicators are federal government officials who preside over administrative hearings and proceedings in a process called adjudication. These officials can be divided into two categories: administrative law judges (ALJs) and non-ALJ adjudicators, sometimes referred to as administrative judges (AJs). Although many of these officials have the word judge in their job title, administrative adjudicators are part of the executive rather than the judicial branch. They are not judges as described in Article III of the Constitution. |
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| Crowell v. Benson | |
| Reference: 285 U.S. 22 | |
| Term: 1932 | |
| Important Dates | |
| Argued: October 20, 21, 1931 Decided: February 23, 1932 | |
| Outcome | |
| Fifth Circuit Court of Appeals affirmed | |
| Majority | |
| Charles Evans Hughes • Willis Van Devanter • James Clark McReynolds • George Sutherland • Pierce Butler • Harlan Fiske Stone • Owen Josephus Roberts | |
| Concurring | |
| None | |
| Dissenting | |
| Louis Dembitz Brandeis | |
Crowell v. Benson is a 1932 United States Supreme Court case that involved a claim for workers compensation, but ultimately decided the constitutionality of administrative adjudication and what deference federal courts owed the findings of administrative hearings at the time. The court held that agency adjudication was constitutional, but that a federal court must review factual questions related to agency jurisdiction or constitutional restrictions de novo, without deference.[1] The case helped define the relationship between administrative agencies and federal courts for the time prior to the 1946 Administrative Procedure Act.
Why it matters: This case was foundational in defining the authority of administrative agencies by upholding administrative adjudication under the U.S. Constitution.[2] It also created a framework for deciding how much deference federal courts owed to administrative agencies.[1]
Timeline
The following timeline details key events in this case:
- February 23, 1932: U.S. Supreme Court decision announced
- October 20 and 21, 1931: Oral argument
- November 17, 1930: The Fifth Circuit Court affirmed the lower court's ruling
- May 27, 1929: The United States District Court for the Southern District of Alabama sent the case to the court of admiralty.
Background
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Knudsen filed for worker’s compensation
Knudsen had been injured on Benson’s boat and filed for worker’s compensation under the Longshoremen's and Harbor Workers' Compensation Acts. Crowell, a deputy commissioner of the U.S. Employees' Compensation Commission, issued a worker's compensation award to Knudsen, who claimed that he was injured while working for Benson. But Benson had lent his boat to a third party when Knudsen was injured, so Benson sought an injunction against the commission who was forcing him to pay the award.[3][1]
Federal courts blocked compensation award
The United States District Court for the Southern District of Alabama reviewed the law and the facts de novo (without deference to a previous interpretation of the underlying statute in question), found that there was no employment relationship, and restrained the award enforcement. Since this case occurred before the Fifth Circuit Court of Appeals Reorganization Act of 1980, the Fifth Circuit court affirmed.[4][1]
Benson argued that the Compensation Act violated the U.S. Constitution
At the U.S. Supreme Court, Benson contended that the Compensation Act had infringed on his constitutional rights of due process and a jury trial by giving judicial authority to Crowell as a deputy commissioner. Benson also argued that the Compensation Act violated the federal court’s authority under Article III of the constitution, while Crowell asserted that the court should not have changed the award to Knudsen or made a de novo review of the facts of the claim.[1]
Question presented
| Question presented: What authority did the agency hearings have to establish facts without infringing on a citizen’s due process rights or the federal court’s authority?[1] |
Oral argument
The court heard oral arguments on October 20 and 21, 1931.[1]
Outcome
The Supreme Court decided 8-1 in favor of Benson. The majority opinion was written by Chief Justice Charles Evans Hughes and joined by Justices Willis Van Devanter, Harlan Fiske Stone, James Clark McReynolds, George Sutherland, Pierce Butler, and Owen Josephus Roberts. Justice Louis Dembitz Brandeis authored a dissenting opinion.[1] Some records of this case claim that Justices Stone, and Roberts joined the dissent.[5]
Opinions
Opinion of the court
Writing for the court, Chief Justice Charles Evans Hughes sought to balance the role of the court with the powers of the new administrative agency. The court found that there were two types of claims an administrative court could hear: those dealing with private rights and those dealing with public rights. In cases of private rights, the court further distinguished between questions of common facts, jurisdictional facts, and constitutional facts.
Public rights
The court defined cases involving public rights as “those which arise between the Government and persons subject to its authority in connection with the performance of the constitutional functions of the executive or legislative departments.”[1] In these cases, the court held that Congress has the power to set up its own system of legislative courts.
Private rights
The court defined cases involving private rights as “the liability of one individual to another under the law."[1] In such cases, courts could rely on some facts found by an agency, but not on jurisdictional or constitutional facts.
The court found that an administrative agency could constitutionally adjudicate claims within its jurisdiction. Further, it ruled that courts should defer to the commonly raised questions of fact within the jurisdiction of the agency:
| “ | ...as to questions of fact arising with respect to injuries to employees within the purview of the Act, the findings of the deputy commissioner, supported by evidence and within the scope of his authority, shall be final. ...The use of the administrative method for these purposes, assuming due notice, proper opportunity to be heard, and that findings are based upon evidence, falls easily within the principle of the decisions sustaining similar procedure against objections under the due process clauses of the Fifth and Fourteenth Amendments.[1][6] | ” |
The court held that questions of fact that raise jurisdictional or constitutional questions must be reviewable by the judicial branch. The court said jurisdictional facts are those which provide the agency with the authority to make a decision.
| “ | Even where the subject lies within the general authority of the Congress, the propriety of a challenge by judicial proceedings of the determinations of fact deemed to be jurisdictional, as underlying the authority of executive officers, has been recognized...This Court has held that matters of this kind, disclosing a want of jurisdiction, may be considered by a court of law. In such cases the objection to the patent reaches beyond the action of the special tribunal, and goes to the existence of a subject upon which it was competent to act.[1][6] | ” |
The court also held that questions of constitutional fact arise when the case turns on the answers to a fact-based inquiry:
| “ | In cases brought to enforce constitutional rights, the judicial power of the United States necessarily extends to the independent determination of all questions, both of fact and law, necessary to the performance of that supreme function. The case of confiscation is illustrative, the ultimate conclusion almost invariably depending upon the decisions of questions of fact. This court has held the owner to be entitled to a fair opportunity for submitting that issue to a judicial tribunal for determination upon its own independent judgment as to both law and facts.[1][6] | ” |
Thus, the majority ruled that an agency may use fact-finding authority, but a federal court may review de novo whether the facts establish that the agency acted constitutionally and within its jurisdiction.
Dissenting opinions
In his dissenting opinion, Justice Louis Dembitz Brandeis argued that any facts determined by an administrative hearing should be binding during judicial review.[1]
| “ | Whatever may be the propriety of a rule permitting special reexamination in a trial court of so-called ‘jurisdictional facts’ passed upon by administrative bodies having otherwise final jurisdiction over matters properly committed to them, I find no warrant for extending the doctrine to other and different administrative tribunals whose very function is to hear evidence and make initial determinations concerning those matters which it is sought to reexamine.[1][6] | ” |
Justice Brandeis insisted that administrative hearings should be able to determine all facts for the agency to have binding authority.[1]
Text of the opinion
Read the full opinion here.
Impact
This case was foundational in defining the authority of administrative agencies by deeming that administrative adjudication is constitutional.[7]
However, subsequent U.S. Supreme Court cases began to chip away at the standard set in Crowell.[8] In 1980 United States v. Raddatz, the U.S. Supreme Court undercut Crowell’s standard.[9] Then in 1984, Chevron v. Natural Resources Defense Council indirectly overruled Crowell’s deference standard.[10]
The right to appeal an adjudication, and that an adjudication’s findings of fact must be supported by evidence, were used in the Administrative Procedure Act of 1946.[11][12]
See also
- Separation of powers
- Deference
- Administrative law
- Supreme Court of the United States
- Judicial review
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 1.13 1.14 1.15 1.16 1.17 United States Supreme Court, Crowell v. Benson February 23,1932.
- ↑ Federal Judicial Center, “Crowell v. Benson,” August 3, 2018
- ↑ “Judicial Review of Administrative Findings. Crowell v. Benson.” The Yale Law Journal 41,7. (1932) 1037-1056.
- ↑ Ainsworth, Robert. “Fifth Circuit Court of Appeals Reorganization Act of 1980.” BYU Law Review 1981, 3. (1981): 523-533.
- ↑ Harvard Law Review, “Crowell v. Benson: Inquiries and Conjectures,” 1933
- ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Federal Judicial Center, “Crowell v. Benson,” August 3, 2018
- ↑ Schwartz, B. Does the ghost of crowell v. benson still walk University of Pennsylvania Law Review 98, 2. (1949):163-182.
- ↑ United States Supreme Court, United States v. Raddatz, June 23, 1980.
- ↑ United States Supreme Court, Chevron, U.S.A., Inc. v. NRDC, Inc, June 25, 1984.
- ↑ 4 Stein, J. & Mitchell, G. (2018). Administrative Law Newark, NJ: Mathew Bender & Co. (§34.02)
- ↑ Legal Information Institute, “5 USC § 556” August 3, 2018
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