Crowell v. Benson

E615010

Crowell v. Benson is a 1932 U.S. Supreme Court decision that helped define the constitutional limits of administrative agencies’ fact-finding powers and the scope of judicial review over administrative adjudications.

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Crowell v. Benson canonical 1

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Statements (47)

Predicate Object
instanceOf United States Supreme Court case
administrative law case
constitutional law case
areaOfLaw administrative law
constitutional law
federal courts
characterizedAs foundational case on constitutional limits of administrative adjudication
chiefJusticeAtDecision Charles Evans Hughes NERFINISHED
citation 285 U.S. 22
constitutionalProvisionInterpreted Article III of the United States Constitution NERFINISHED
Due Process Clause of the Fifth Amendment NERFINISHED
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1932
hasInfluenceOn development of modern administrative law
later Supreme Court cases on Article III and administrative tribunals
scope of judicial review over agency adjudications
holding Administrative findings of ordinary or non-jurisdictional facts may be treated as final if supported by evidence and if judicial review is available for questions of law and jurisdiction.
Article III courts must retain the power to make independent determinations of constitutional facts and jurisdictional facts.
Congress may assign initial fact-finding in certain cases to administrative agencies or non-Article III tribunals under limited conditions.
The use of administrative agencies for initial adjudication does not necessarily violate Article III if adequate judicial review is preserved.
involvedStatute Longshoremen's and Harbor Workers' Compensation Act NERFINISHED
issue Whether Congress could authorize an administrative agency to make binding findings of fact in compensation cases subject to limited judicial review.
Whether the delegation of adjudicatory authority to an administrative officer violated Article III.
jurisdiction United States of America
surface form: United States
languageOfCase English
legalPrinciple compatibility of administrative adjudication with Article III under certain safeguards
constitutional limits on delegation of adjudicatory power to administrative agencies
distinction between jurisdictional facts and ordinary facts in administrative adjudication
requirement of judicial review of constitutional and jurisdictional questions decided by agencies
majorityOpinionBy Charles Evans Hughes NERFINISHED
publicationType official United States Reports opinion
relatedCase Commodity Futures Trading Commission v. Schor NERFINISHED
Northern Pipeline Construction Co. v. Marathon Pipe Line Co. NERFINISHED
Stern v. Marshall NERFINISHED
Thomas v. Union Carbide Agricultural Products Co. NERFINISHED
relatedConcept administrative fact-finding
constitutional fact doctrine
judicial review of administrative action
non-Article III tribunals
public rights doctrine
separation of powers
result The Supreme Court upheld the basic administrative scheme but required independent judicial determination of constitutional and jurisdictional facts.
setsPrecedentFor judicial review of agency determinations of jurisdictional facts
treatment of agency findings of fact as final when supported by evidence
timePeriod Lochner–New Deal era of Supreme Court jurisprudence NERFINISHED
yearDecided 1932

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