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.

All labels observed (1)

Label Occurrences
Crowell v. Benson canonical 1

How this entity was disambiguated

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 ⓘ
citation 285 U.S. 22 ⓘ
constitutionalProvisionInterpreted Article III of the United States Constitution ⓘ
Due Process Clause of the Fifth Amendment ⓘ
linked to: Due Process Clause
country 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 ⓘ
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 ⓘ
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 ⓘ
publicationType official United States Reports opinion ⓘ
relatedCase Commodity Futures Trading Commission v. Schor ⓘ
Northern Pipeline Construction Co. v. Marathon Pipe Line Co. ⓘ
Stern v. Marshall ⓘ
Thomas v. Union Carbide Agricultural Products Co. ⓘ
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 ⓘ
yearDecided 1932 ⓘ

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Referenced by (1)

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