Also known as: Article I courts · legislative court · Art. I court
Written by attorneys — see sources below.
A federal tribunal established by Congress under its Article I legislative powers to adjudicate disputes arising within federal regulatory or benefits programs. Its judges serve fixed terms without life tenure or salary protection and may combine administrative rulemaking with adjudicative functions.
Atlas Ventures sued Alpine Mining in bankruptcy court for breach of a state-law supply contract. The bankruptcy judge entered final judgment awarding damages. Because the claim was a traditional private-party contract dispute rather than a public-rights matter integral to the bankruptcy estate, the district court withdrew the reference and required an Article III judge to decide the case.
Congress created the Federal Agricultural Claims Court inside the Department of Agriculture to set subsidy rules and decide payment disputes. Alexandra Armstrong challenged a denial of her crop-loss claim, arguing the judges lacked Article III protections. The court rejected the challenge because the tribunal performed both administrative and adjudicative tasks within a federal benefits program.
Audrey Ashton was sentenced under guidelines issued by the United States Sentencing Commission. She argued the Commission violated separation of powers because its members lacked life tenure. The reviewing court upheld the guidelines, recognizing that Congress may create Article I bodies to perform specialized functions incidental to its legislative powers.
In 1984, Congress enacted the Sentencing Reform Act to address widespread criticisms that federal sentencing was a national scandal marked by unwarranted disparities and uncertainty. The legislation created the United States Sentencing Commission as an independent commission in the judicial branch consisting of seven voting members. The President appoints the members with the advice and consent of the Senate, and at least three members must be federal judges selected after consideration of recommendations from the Judicial Conference of the United States, while the Attorney General serves as an ex officio nonvoting member. Petitioner John M. Mistretta was indicted in the United States District Court for the Western District of Missouri on three counts centering on a cocaine sale. He pleaded guilty to one count of conspiracy to distribute cocaine. The district court sentenced him under the Guidelines to 18 months' imprisonment to be followed by a three-year term of supervised release, along with a $1,000 fine and a $50 assessment. Mistretta appealed his sentence to the United States Court of Appeals for the Eighth Circuit, challenging the constitutionality of the Sentencing Commission and the Guidelines. Both Mistretta and the United States petitioned the Supreme Court for certiorari before judgment in the Eighth Circuit. The Court granted the petitions because of the imperative public importance of the issue and the disarray among the federal district courts.
View caseAnika Anand obtained a final judgment in federal district court against Antonio Alvarado. Congress later enacted a statute directing Article I tribunals to reopen and reconsider such judgments. The district court refused to give effect to the statute, holding that Congress cannot use legislative courts to override completed Article III adjudications.
In 1987 petitioners filed a civil action in the United States District Court for the Eastern District of Kentucky against respondents. The complaint alleged that respondents had committed fraud and deceit in the sale of stock in 1983 and 1984 in violation of section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5. The District Court dismissed the action as time barred under the then-applicable Kentucky statute of limitations. While petitioners' appeal was pending in the Court of Appeals for the Sixth Circuit, the Supreme Court decided Lampf, Pleva, Lipkind, Prupis & Petigrow v. Gilbertson on June 20, 1991. The next day the Court applied that decision to dismiss another pending appeal. The Sixth Circuit remanded petitioners' case to the District Court for further proceedings in light of Lampf. On August 13, 1991, the District Court dismissed the action with prejudice under the Lampf statute of limitations. Petitioners filed no appeal, and the judgment became final thirty days later on December 18, 1991. On December 19, 1991, the President signed the Federal Deposit Insurance Corporation Improvement Act of 1991. Section 476 of that Act added section 27A to the Securities Exchange Act of 1934. Subsection (b) provides that any private civil action under section 10(b) commenced on or before June 19, 1991, which was dismissed as time barred after that date and which would have been timely under the limitation period provided by the laws applicable in the jurisdiction as such laws existed on June 19, 1991, shall be reinstated on motion by the plaintiff not later than sixty days after December 19, 1991. Petitioners promptly filed a motion under section 27A(b) to reinstate their action. The District Court denied the motion. The Court of Appeals for the Sixth Circuit reversed, and the Supreme Court granted certiorari.
View caseAriana Azizi sought compensation for a workplace injury before a deputy commissioner in the Department of Labor. The commissioner made findings of fact and entered an award. The reviewing court upheld the procedure, confirming that Congress may assign fact-finding in public-rights disputes to non-Article III officers as part of a regulatory scheme.
Knudsen filed a claim for compensation against Benson under the Longshoremen's and Harbor Workers' Compensation Act with Deputy Commissioner Crowell of the United States Employees' Compensation Commission. The evidence introduced before the deputy commissioner was directed largely to the employment issue and was conflicting. After considering the evidence the deputy commissioner found that Knudsen was in Benson's employ at the time of the injury and filed an order for compensation. Benson then brought suit in the United States District Court to enjoin enforcement of the award. Benson alleged that Knudsen was not his employee at the time of the injury and that the claim lay outside the deputy commissioner's jurisdiction. An amended complaint further challenged the constitutionality of the Act on multiple grounds. Those grounds included alleged violations of the due process clause of the Fifth Amendment, the Seventh Amendment right to jury trial, the Fourth Amendment prohibition on unreasonable searches and seizures, and the judicial power provisions of Article III. The District Judge denied motions to dismiss and granted a hearing de novo upon the facts and the law. The case was transferred to the admiralty docket, answers were filed presenting the issue as to the fact of employment, and the evidence of both parties having been heard, the District Court decided that Knudsen was not in the employ of the petitioner and restrained the enforcement of the award. The decree was affirmed by the Circuit Court of Appeals, and this Court granted writs of certiorari.
View caseAlan Ackerman filed a federal action seeking custody and support orders against his former spouse. The district court dismissed the case, explaining that Congress has not authorized Article I or Article III federal courts to adjudicate core domestic-relations matters traditionally reserved to state courts.
In September 1989 Carol Ankenbrandt, a citizen of Missouri, filed suit in the United States District Court for the Eastern District of Louisiana on behalf of her daughters L. R. and S. R. against Jon A. Richards and Debra Kesler, both citizens of Louisiana. The complaint alleged that Richards, the divorced father of the children, and Kesler, his female companion, had committed acts of sexual and physical abuse against the daughters and sought monetary damages. Federal jurisdiction rested solely on the diversity-of-citizenship provision of 28 U.S.C. § 1332. One month earlier, on August 9, 1989, a juvenile court in Jefferson Parish, Louisiana, had entered a judgment under state child-protection statutes that permanently terminated Richards' parental rights on account of the alleged abuse and permanently enjoined him from any contact with the children. On December 10, 1990, the District Court granted the respondents' motion to dismiss. The court cited In re Burrus for the proposition that the whole subject of domestic relations belongs to the laws of the States and invoked the domestic relations exception to diversity jurisdiction. It also relied on the abstention principles of Younger v. Harris to dismiss the complaint without prejudice. The Court of Appeals for the Fifth Circuit affirmed in an unpublished opinion. The Supreme Court granted certiorari limited to three questions concerning the existence and scope of any domestic relations exception and the propriety of Younger abstention in the case.
View caseArticle I courts are created by Congress under its legislative powers and their judges lack life tenure and salary protection. Article III courts exercise the judicial power of the United States and their judges receive those constitutional protections.
No. Congress may not assign wholesale to Article I courts cases of the type traditionally heard by Article III courts, such as state-law contract claims between private parties.
Congress may create such hybrid tribunals when the adjudicative function is incidental to implementing a federal regulatory or benefits program and the matters involve public rights.
No. The lack of life tenure is permissible so long as the tribunal adjudicates public-rights matters within a legislative scheme rather than exercising the core judicial power of the United States.
…over members of another Branch. Indeed, we already have recognized that the President may remove a judge who serves on an Article I court. McAllister v. United States , 141 U. S. 174, 185 (1891). In any event, we hold here no more than that Congress may vest in the President the power to remove for good cause an Article…