Crowell v. Benson

Crowell v. Benson
Supreme Court of the United States
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
Holding
Court membership
Chief Justice Charles E. Hughes Associate Justices Oliver W. Holmes, Jr. · Willis Van Devanter James C. McReynolds · Louis Brandeis George Sutherland · Pierce Butler Harlan F. Stone · Owen J. Roberts
Case opinions
Majority	Hughes
Dissent	Brandeis

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.

The decision

Justice Hughes 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."

The dissent

Justice Brandeis argued that "[t]o permit a content 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.

See also

• List of United States Supreme Court cases, volume 285

External links

• Text of Crowell v. Benson, 285 U.S. 22 (1932) is available from: Justia · Findlaw