Crowell v. Benson, 285 U.S. 22 (1932)
Fact-finding authority can be assigned to a tribunal other than a court by a law enacted by Congress, but a federal court can review under a de novo standard whether the facts in a certain case establish the applicability of the law in that case.
Knudsen alleged that he had been hurt while working for Benson, and he sought compensation under the Longshoremen's and Harbor Workers' Compensation Act. Crowell, a deputy commissioner of the U.S. Employees' Compensation Commission, issued an award to Knudsen. Benson sought to enjoin the enforcement of the award on the grounds that Knudsen had not been working for him when he was hurt. A federal court agreed that there was no employment relationship and issued an order restraining the award after it reviewed the law and the facts de novo. When Crowell sought certiorari at the 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. He also argued that the Compensation Act violated Article III, while Crowell argued that the court should not have disturbed the award to Knudsen or engaged in a de novo review of the facts of the claim.Opinions
- Charles Evans Hughes (Author)
- Willis Van Devanter
- James Clark McReynolds
- George Sutherland
- Pierce Butler
- Harlan Fiske Stone
- Owen Josephus Roberts
While Congress might have intended the factual conclusions of the deputy commissioner to have finality, the issue of whether an employment relationship existed related to the commissioner's jurisdiction. If there was no employment relationship, the Compensation Act would not apply, and the deputy commissioner would not have been permitted to review the case. The court had the authority to make this determination, therefore, and it acted properly in conducting the hearing de novo. The evidence clearly shows that the award should not have been issued because there was no employment relationship at the time of the accident.
- Louis Dembitz Brandeis (Author)
A judicial factual determination in a civil proceeding can be based on evidence from an administrative hearing without infringing on the independence of the judicial branch under Article III. The decision of the deputy commissioner that an employment relationship existed should have been treated as final because it was only a quasi-jurisdictional determination. The Constitution does not prevent denying a de novo review of these factual findings, and Congress has the power to determine the scope of the jurisdiction of federal courts to hear the first instance of controversies. Administrative tribunals may be equipped to handle these hearings unless it would result in a violation of due process. This concern does not arise in civil cases based on disputes over property rights.Case Commentary
Congress also has the power to give some forms of legislative functions to administrative agencies, but the Administrative Procedure Act usually provides a right to judicial review of those decisions. In general, though, Congress does have the authority to remove matters from the consideration of federal district courts that they normally would be able to review.
U.S. Supreme CourtCrowell v. Benson, 285 U.S. 22 (1932)
Crowell v. Benson
Argued October 20, 21, 1931
Decided February 23, 1932*
285 U.S. 22
1. In virtue of its power to alter or revise the maritime law, Congress may provide that, where employees in maritime employment are disabled or die from accidental injuries arising out of or in the course of their employment upon the navigable waters of the United States, their employers shall pay reasonable compensation, without regard to fault as the cause of injury, and be thereby relieved from other liability. P. 285 U. S. 39.
2. The Longshoremen's and Harbor Workers' Compensation Act, which provides a scheme for compensation in the class of cases above described, applicable if recovery "through workmen's compensation proceedings may not validly be provided by State law," upheld as to substantive provisions. P. 285 U. S. 22.
3. The classifications of disabilities and beneficiaries and the amounts of compensation provided in the Act not being unreasonable, the Act in those respects is consistent with the due process clause of the Fifth Amendment. Pp. 285 U. S. 41-42.
4. The difficulty of ascertaining actual damages justifies the fixing of standard compensation in such an Act at figures reasonably approximating probable damages. Id.
5. Considerations respecting the relation of master and servant, which sustain workmen's compensation laws of the States against objections under the due process clause of the Fourteenth Amendment, are applicable to the substantive provisions of this Act of Congress, tested by the due process clause of the Fifth Amendment. Id.
6. Claims for compensation under the above-mentioned Act are filed with administrative officers called deputy commissioners, who "shall have full power and authority to hear and determine all questions in respect of such claim." They may issue subpoenas which are enforceable through contempt proceedings in federal courts. In investigating
and hearing claims they, are not to be bound by the common law or statutory rules of evidence, except as provided in the Act, but are to proceed in such manner "as to best ascertain the rights of the parties." Hearings are to be public and reported stenographically, and records are to be made for which the Commission created by the Act must provide by regulation. Orders for compensation are to become final in 30 days. When compensation ordered is not paid, a supplementary order may be made declaring the amount in default, and judgment for that amount may be entered in a federal court if the order "is in accordance with law." Review of such judgment may be had as in suits for damages at common law. The Act further provides that, if a compensation order is "not in accordance with law," it may be suspended or set aside, in whole or in part, through injunction proceedings against the deputy commissioner who made it; and also that beneficiaries of such an order, or the deputy commissioner, may have it enforced in a federal court if the court determines that the order " was made and served in accordance with law."
(1) As the claims are governed by the maritime law and within the admiralty jurisdiction, trial by jury is not required by the Seventh Amendment. P. 285 U. S. 45.
(2) The Act reserves to the admiralty courts full power to pass upon all questions of law, including the power to deny effect to an administrative finding which is without evidence or contrary to the indisputable character of the evidence, or where the hearing was inadequate, unfair, or arbitrary. In this respect it, satisfies due process and attempts no interference with the judicial power in admiralty and maritime cases. Pp. 285 U. S. 46, 285 U. S. 49.
(3) As regards questions of fact, the Act does not expressly preclude the court, in proceedings to set aside an order as not in accordance with law, from making its own examination and determination of facts whenever that is deemed necessary to enforce constitutional rights; and, as the Act is to be construed to support, rather than to defeat it, no such limitation should be implied. P. 285 U. S. 46.
(4) Apart from constitutional rights to be enforced in court, the Act contemplates that, in cases within its purview, the findings of a deputy commissioner on questions of fact respecting injuries to employees shall be final if supported by evidence. P. 285 U. S. 46.
(5) So limited, the use of the administrative method for determining facts (assuming due notice and opportunity to be heard and that findings are based upon evidence) is consistent with due process
and is not an unconstitutional invasion of the judicial power. Pp. 285 U. S. 47, 285 U.S. 51.
(6) The Act requires a public hearing, and that all proceedings upon a particular claim shall be shown in the record and open to challenge and opposing evidence; facts known to the deputy commissioner but not put in evidence will not support a compensation order. P. 285 U. S. 48.
(7) The provision that the deputy commissioner shall not be bound by the rules of evidence applicable in a court or by technical rules of procedure is compatible with due process provided the substantial rights of the parties be not infringed. Id.
(8) Equipping the admiralty courts with power of injunction, for enforcing the standards of maritime law as defined by the Act, is consistent with Art. III of the Constitution. P. 285 U. S. 49.
(9) Where the question of fact relates to either of the two fundamental and jurisdictional conditions of the statute, viz., (a) occurrence of the injury upon navigable waters of the United States, and (b) existence of the relation of master and servant, the finding of the deputy commissioner is not conclusive, but the question is determinable de novo by the court on full pleadings and proofs in a suit for an injunction, in which the court is not confined to the evidence taken and record made before the deputy commissioner. The statute is susceptible of this construction, and must be so construed to avoid unconstitutionality. Pp. 285 U. S. 54, 285 U. S. 62.
(10) In amending and revising the maritime law, Congress can not reach beyond the constitutional limits of the admiralty and maritime jurisdiction. P. 285 U. S. 55.
(11) Congress has no general authority to amend the maritime law so as to establish liability without fault in maritime cases regardless of particular circumstances or relations -- in this instance, the relation of master and servant. P. 285 U. S. 56.
7. As respects the power of Congress to provide for determinations of fact otherwise than through the exercise of the judicial power reposed by the Constitution in the courts of the United States, a clear distinction exists between cases arising between the Government and other persons which, by their nature, do not require judicial determination (though they may be susceptible of it) and cases of private right, that is, of the liability of one individual to another under the law as defined. P. 285 U. S. 50.
8. Proper maintenance of the federal judicial power in enforcing constitutional restrictions precludes a power in Congress to substitute for constitutional courts, in which the judicial power of the United
States is vested, an administrative agency for the final determination of facts upon which the enforcement of the constitutional rights of the citizen depend. P. 285 U. S. 56.
9. A State, on the other hand, may distribute its powers as it sees fit, provided only that it acts consistently with the essential demands of due process and does not transgress restrictions of the Federal Constitution applicable to state authority. P. 285 U. S. 57.
10. The power of Congress to change the procedure of the courts of admiralty would not justify lodging in an administrative officer final decision of facts upon which the constitutional rights of individuals are dependent. P. 285 U. S. 61.
11. In deciding upon the validity of an Act of Congress, regard must be had to substance, rather than form. P. 285 U. S. 53.
12. Where the validity of an Act of Congress is drawn in question or where a serious doubt of its constitutionality is raised, it is a cardinal principle that the court will first ascertain whether a construction of the Act is fairly possible by which the question may be avoided. P. 285 U. S. 62.
13. A declaration in a statute that if any of its provisions, or the application thereof to any persons or circumstances, shall be found unconstitutional, the validity of the remainder of the statute and the applicability of its provisions to other persons or circumstances shall not be affected evidences an intention that no implication from the terms of the Act which would render them invalid should be indulged. P. 285 U. S. 63.
45 F.2d 66, affirmed.
Certiorari, 283 U.S. 814, to review a decree which affirmed a decree of the District Court, 33 F.2d 137; 38 id. 306, enjoining the enforcement of an award of compensation made by a deputy commissioner under the Longshoremen's and Harbor Workers' Compensation Act.