Northern Pipeline Construction Co. v. Marathon Pipe Line Co.
Citation and Court
458 U.S. 50 (1982), Supreme Court of the United States
Facts
Northern Pipeline filed for bankruptcy. As part of its reorganization, it filed a state-law breach of contract claim against Marathon Pipe Line in bankruptcy court. Marathon challenged the jurisdiction of the bankruptcy court — a non-Article III tribunal — to adjudicate the state-law contract claim.
Issue
Whether Congress may vest a non-Article III bankruptcy court with jurisdiction to adjudicate state-law contract claims that arise in the context of a bankruptcy proceeding.
Holding
Congress may not vest a non-Article III court with jurisdiction to adjudicate state-law contract claims; such claims are quintessentially private rights that must be resolved by Article III courts.
Rule / Doctrine
Congress has broad power to create non-Article III courts for matters involving “public rights” — disputes arising between the government and private parties, or matters arising from a federal regulatory scheme. But disputes between private parties over state-law rights (private rights) must be adjudicated by Article III courts with life tenure and salary protections.
Significance
Northern Pipeline is a landmark Article III case that strictly limited the authority of non-Article III tribunals to adjudicate private rights. It prompted the current statutory regime governing bankruptcy court jurisdiction (28 U.S.C. § 157) and remains a leading case on the constitutional distinction between public and private rights in administrative adjudication.