Crowell v. Benson
Citation and Court
Crowell v. Benson, 285 U.S. 22 (1932). United States Supreme Court.
Facts
A deputy commissioner under the Longshoremen’s and Harbor Workers’ Compensation Act determined that one of Benson’s employees was injured in the course of employment and awarded compensation. Benson challenged the constitutionality of the Act, arguing that allowing an administrative officer — rather than an Article III judge — to make binding factual findings violated the separation of powers. The district court agreed and conducted a de novo hearing on the jurisdictional facts.
Issue
Whether Congress may constitutionally assign factfinding authority in workers’ compensation cases to a non-Article III administrative tribunal, subject only to limited judicial review.
Holding
The Supreme Court upheld the Compensation Act as applied to “public rights” and statutory-rights adjudications but held that Article III courts retain independent power to determine “constitutional facts” — facts upon which constitutional jurisdiction depends — by de novo review.
Rule / Doctrine
Congress may assign adjudication of “public rights” (rights created by federal statute against the government) and certain private-rights disputes with limited judicial review to non-Article III tribunals. However, when a fact is “jurisdictional” in a constitutional sense — i.e., the fact determines whether the constitutional grant of federal court jurisdiction applies — courts must be able to review that fact de novo.
Significance
Crowell v. Benson is the foundational case on the constitutional limits of administrative adjudication. It introduces the public rights / private rights distinction that continues to structure Article III jurisprudence, and the concept of “constitutional facts” that courts may review independently. Though the “constitutional facts” doctrine has rarely been applied, the broader public/private rights framework remains central to cases like Stern v. Marshall.