Crowell v. Benson

Crowell v. Benson, 285 U.S. 22 (1932) is the landmark United States Supreme Court administrative law decision that outlined the adjudicatory authority of administrative agencies under Article III of the Constitution. 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. 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. The District Court affirmed the award. Writing for the Court, Chief Justice Hughes reaffirmed the lower court holding. The Court first addressed the plaintiff's argument that the enforcement of the award against him unconstitutionally deprived him of property without due process of law, therefore violating the Fifth Amendment to the United States Constitution. Specifically, Benson argued that the process by which an administrative agency was empowered to make findings of fact was insufficient. The Court held that the statute did not violate the due process clause because the administrative procedure provided notice, an opportunity to be heard, findings based on record evidence, and judicial review of all questions of law. Next, the Court turned to whether the statute unconstitutionally bestowed judicial power upon a non-judicial authority in violation of the vesting clause of Article III of the United States Constitution, that is, "whether Congress may substitute for constitutional courts, in which the judicial power of the United States is vested, an administrative agency... for the final determination of the facts upon which the enforcement of the constitutional rights of the citizen depend.