Also known as: Article III court · Article 3 court · Article 3 courts · art. III court · art. III courts · Art. III courts
Written by attorneys — see sources below.
Federal courts established by Congress pursuant to Article III of the Constitution. Judges of these courts hold office during good behavior and receive compensation that cannot be diminished during their continuance in office.
SkyWind LLC filed an adversary proceeding in bankruptcy court against Horizon Utility Corp. alleging breach of a prepetition state-law power purchase agreement. Horizon objected that the bankruptcy judge lacked authority to enter final judgment. The objection was sustained because the claim was a traditional state-law contract action between private parties.
After filing for bankruptcy, a debtor asserted a state-law tort counterclaim against a creditor in bankruptcy court. The creditor moved to withdraw the reference. The motion was granted because the counterclaim did not stem from the bankruptcy itself and required resolution by an Article III judge.
Vickie Lynn Marshall married J. Howard Marshall II, Pierce Marshall’s father, approximately one year before J. Howard’s death. Shortly before J. Howard died, Vickie filed suit against Pierce in Texas state probate court asserting that Pierce had tortiously interfered with a gift J. Howard intended to provide her through a trust. After J. Howard’s death, Vickie filed a petition for bankruptcy in the United States Bankruptcy Court for the Central District of California. Pierce filed a proof of claim in the bankruptcy proceeding asserting a defamation claim against Vickie’s estate arising from statements made to the press by Vickie’s lawyers accusing him of fraud in controlling his father’s assets. Vickie responded by filing a counterclaim for tortious interference with the expected gift from J. Howard. On November 5, 1999, the Bankruptcy Court granted Vickie summary judgment on Pierce’s defamation claim. After a bench trial, on September 27, 2000, the Bankruptcy Court entered judgment for Vickie on her counterclaim and later awarded her over $400 million in compensatory damages and $25 million in punitive damages. The District Court concluded that Vickie’s counterclaim was not a core proceeding under 28 U.S.C. §157(b)(2)(C) and therefore treated the Bankruptcy Court’s judgment as proposed findings of fact and conclusions of law. The District Court conducted an independent review of the record. It declined to give preclusive effect to a Texas state court judgment that had been entered in Pierce’s favor. The District Court awarded Vickie compensatory and punitive damages, each in the amount of $44,292,767.33. The Court of Appeals for the Ninth Circuit reversed. It held that the Bankruptcy Court lacked authority to enter final judgment on Vickie’s counterclaim because the counterclaim was not so closely related to Pierce’s proof of claim that its resolution was necessary to resolve the allowance or disallowance of that claim. This holding made the Texas probate court judgment the earliest final judgment, which the Court of Appeals held the District Court should have afforded preclusive effect. The Supreme Court granted certiorari.
View caseForeign nationals and states sued in federal district court to enjoin a presidential proclamation restricting entry from certain countries. The district court entered a nationwide injunction. The injunction was reviewed by Article III courts exercising the full judicial power over constitutional claims.
Shortly after taking office, President Trump signed Executive Order 13769 directing a review of information provided by foreign governments about their nationals seeking entry and temporarily restricting entry from seven countries previously identified as posing terrorism risks. After courts enjoined that order, the President revoked it and issued Executive Order 13780, which again directed a worldwide review and temporarily restricted entry from six of the countries. Following completion of the review, the President issued Proclamation No. 9645 on September 24, 2017, placing entry restrictions on nationals of eight countries—Chad, Iran, Iraq, Libya, North Korea, Syria, Venezuela, and Yemen—whose systems for managing and sharing information the President deemed inadequate. The Proclamation imposed varying restrictions by country, exempted lawful permanent residents and asylees, provided for case-by-case waivers, and directed ongoing 180-day reviews; restrictions on Chad were later lifted after it improved its practices. Plaintiffs including the State of Hawaii, three U.S. citizens with foreign-national relatives from Iran, Syria, and Yemen applying for visas, and the Muslim Association of Hawaii challenged the Proclamation in the District of Hawaii on statutory and Establishment Clause grounds. The district court granted a nationwide preliminary injunction. The Ninth Circuit affirmed on statutory grounds. The Supreme Court granted certiorari.
View caseA photographer obtained a jury verdict in federal district court for lost transparencies. The court of appeals applied state law to reduce the award. The reduction was reviewed under standards preserving the role of Article III courts and the Seventh Amendment jury trial right.
William Gasperini, a journalist and photographer who had taken over 5,000 slide transparencies while reporting in Central America, agreed in 1990 to supply 300 of his original color transparencies to The Center for Humanities, Inc., for use in an educational videotape titled Conflict in Central America. After the project concluded, the Center could not locate or return the transparencies, prompting Gasperini to pursue legal remedies for their loss. Gasperini, a California citizen, sued the Center, a New York corporation with its principal place of business in New York, in the United States District Court for the Southern District of New York. He invoked diversity jurisdiction under 28 U.S.C. § 1332 and alleged state-law claims for breach of contract, conversion, and negligence. The Center conceded liability, so the case proceeded to trial solely on damages. At the three-day jury trial, Gasperini's expert testified that the industry standard valued each lost transparency at $1,500 as the average license fee over the photographer's copyright term. Gasperini testified that his photography earnings from 1984 through 1993 totaled just over $10,000 and that he planned to publish a book of his best Central American photographs. The jury returned a verdict of $450,000, or $1,500 for each of the 300 slides. The Center moved for a new trial under Federal Rule of Civil Procedure 59, invoking both the federal standard and New York Civil Practice Law and Rules § 5501(c). The District Court denied the motion without comment. The Court of Appeals for the Second Circuit vacated the judgment after applying the New York deviates-materially standard itself. The Second Circuit surveyed Appellate Division decisions on similar awards and concluded that the verdict materially deviated from reasonable compensation because many slides were generic and Gasperini had limited earnings. It ordered a new trial unless Gasperini accepted a reduction to $100,000. The Supreme Court granted certiorari to resolve the conflict over the proper standard.
View caseA college challenged a government conveyance of surplus property to a religious organization. The organization moved to dismiss for lack of standing. The motion was granted because the plaintiffs failed to allege a concrete injury redressable by an Article III court.
In 1942 the Department of the Army acquired approximately 181 acres northwest of Philadelphia and constructed the Valley Forge General Hospital on the site. The hospital provided medical care to members of the Armed Forces for the next thirty years. In April 1973 the Secretary of Defense proposed closing the installation as part of a plan to reduce the number of military facilities in the United States, after which the General Services Administration declared the property surplus. In August 1976 the Department of Health, Education, and Welfare conveyed a 77-acre tract of the former hospital grounds to petitioner Valley Forge Christian College. The appraised value of the tract at the time of transfer was $577,500, but the Secretary applied a 100 percent public benefit allowance that allowed the college to take title without any cash payment. The deed conveyed the land in fee simple subject to conditions subsequent that required the college to use the property for thirty years solely for the educational purposes described in its application. Valley Forge Christian College is a nonprofit educational institution operating under the supervision of the Assemblies of God. Its stated purpose is to offer systematic collegiate training to men and women for Christian service as ministers or laymen, and its degree programs are designed to train leaders for church-related ministries. Faculty members must have been baptized in the Holy Spirit and be living consistent Christian lives, and all members of the college administration must be affiliated with the Assemblies of God. In September 1976 respondents Americans United for Separation of Church and State, Inc., a nonprofit organization with approximately 90,000 taxpayer members, and four of its employees learned of the conveyance through a news release. Two months later they filed suit in the United States District Court for the District of Columbia, later transferred to the Eastern District of Pennsylvania, seeking a declaration that the conveyance was null and void and an order requiring the college to return the property to the United States. The District Court granted summary judgment and dismissed the complaint, finding that respondents lacked standing as taxpayers and had failed to allege any actual or concrete injury beyond a generalized grievance common to all taxpayers. The Court of Appeals for the Third Circuit reversed by a divided vote. It held that respondents possessed standing as citizens claiming injury in fact to their shared individuated right to a government that shall make no law respecting the establishment of religion. The Supreme Court granted certiorari in 1981.
View caseThe City of New York and health care providers sued to challenge the President's cancellation of spending provisions under a new statute. The district court declared the cancellations unconstitutional. The Supreme Court affirmed because the cancellations altered the legal rights and duties of affected parties in a manner requiring resolution by Article III courts.
In April 1996 Congress enacted the Line Item Veto Act, which took effect on January 1, 1997, and authorized the President to cancel in whole any dollar amount of discretionary budget authority, any item of new direct spending, or any limited tax benefit. On August 5, 1997, Congress passed the Balanced Budget Act of 1997, which included section 4722(c) deeming certain New York health-care-provider taxes permissible and in compliance with federal Medicaid requirements. On the same day Congress passed the Taxpayer Relief Act of 1997, which included section 968 granting a limited tax benefit allowing owners of certain food refiners and processors to defer recognition of gain when selling stock to eligible farmers' cooperatives. On August 11, 1997, President Clinton transmitted notices canceling section 4722(c) of the Balanced Budget Act and section 968 of the Taxpayer Relief Act. The City of New York, two hospital associations, one hospital, and two unions representing health-care employees filed suit challenging the cancellation of section 4722(c). Snake River Potato Growers, Inc., a farmers' cooperative formed in May 1997 to acquire potato-processing facilities, and one of its members filed a separate action challenging the cancellation of section 968. The District Court for the District of Columbia consolidated the two actions and held that at least one plaintiff in each case had Article III standing. It ruled on the merits that the cancellations did not conform to the constitutionally mandated procedures for the enactment or repeal of laws. Earlier, six Members of Congress who had voted against the Line Item Veto Act had brought a separate challenge; the District Court had held the Act unconstitutional, but the Supreme Court dismissed that action for lack of standing in Raines v. Byrd, 521 U.S. 811 (1997). After the President exercised the cancellation authority, the present appellees filed suit challenging the two cancellations, and the District Court again held the statute invalid.
View caseJudges receive lifetime tenure during good behavior and compensation that cannot be diminished while they remain in office. These protections ensure judicial independence from the political branches. Bodies whose members serve fixed terms and lack salary protection cannot exercise the judicial power reserved to Article III courts.
No. Congress may not take cases of the type traditionally heard by Article III courts and assign them wholesale to Article I courts. A state-law contract claim between private parties remains the kind of dispute historically resolved only by Article III judges. The bankruptcy court therefore lacks authority to enter final judgment on such a claim.
Congress may create Article I tribunals to administer federal regulatory schemes and resolve disputes arising under those schemes. Such tribunals may combine rulemaking and adjudication when their work is tied to implementation of congressionally created rights. They may not, however, adjudicate traditional private-rights disputes that fall within the judicial power vested exclusively in Article III courts.