Also known as: legislative court · Article I courts · Article 1 courts
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A federal tribunal established by Congress under its Article I powers to adjudicate matters outside the core judicial power of the United States. Its presiding officers lack the life tenure and salary protections required for Article III judges. Such tribunals often combine administrative and adjudicative functions within a federal regulatory scheme.
Lars Lindstrom, a supplier, sues a private buyer in bankruptcy proceedings over an unpaid state-law contract for equipment delivery. The new statute routes the entire claim to a bankruptcy court whose judges serve fixed terms. The court enters final judgment against the buyer. The assignment of this traditional private contract action to the non-Article III forum exceeds constitutional limits.
Luke Latham operates a farm that participates in a federal subsidy program. Congress places the claims tribunal inside the Department of Agriculture and tasks it with both issuing program rules and deciding payment disputes. The tribunal's judges serve staggered eight-year terms. The structure is permissible because the body performs integrated administrative and judicial functions tied to a congressional benefits scheme.
Leo Lynch, an injured longshore worker, seeks benefits from an administrative tribunal created to administer a federal compensation statute. The tribunal makes factual findings on the extent of disability and issues a binding award. Its judges lack life tenure. The arrangement is constitutional because the tribunal functions as an adjunct resolving claims created by federal statute.
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 caseLuis Lopez, a bankruptcy trustee, sues a private company in bankruptcy court to recover an alleged fraudulent conveyance under state law. The defendant demands a jury trial. The bankruptcy judges lack Article III protections. The claim must be tried in an Article III court because it is a private-rights action historically resolved by juries.
The Chase & Sanborn Corporation filed a petition for reorganization under Chapter 11 of the Bankruptcy Code in 1983. A plan approved by the United States Bankruptcy Court for the Southern District of Florida then vested in respondent Nordberg, the trustee in bankruptcy, causes of action for fraudulent conveyances. In 1985 respondent filed suit against petitioners Granfinanciera, S. A., and Medex, Ltda., in the United States District Court for the Southern District of Florida, alleging that petitioners had received $1.7 million from Chase & Sanborn's corporate predecessor within one year of the bankruptcy petition without receiving consideration or reasonably equivalent value. The complaint sought to avoid the transfers and recover damages under 11 U. S. C. §§ 548(a)(1) and (a)(2), 550(a)(1) (1982 ed. and Supp. V). The District Court referred the proceedings to the Bankruptcy Court. Over five months later respondent served a summons on petitioners in Bogota, Colombia shortly before the Colombian Government nationalized Granfinanciera. In their answer both petitioners requested a trial by jury on all issues so triable. The Bankruptcy Judge denied petitioners' request for a jury trial, deeming a suit to recover a fraudulent transfer a core action that originally, under the English common law, as I understand it, was a non-jury issue. Following a bench trial, the court dismissed with prejudice respondent's actual fraud claim but entered judgment for respondent on the constructive fraud claim in the amount of $1,500,000 against Granfinanciera and $180,000 against Medex. The District Court affirmed without discussing petitioners' claim that they were entitled to a jury trial. The Court of Appeals for the Eleventh Circuit also affirmed, 835 F. 2d 1341 (1988), ruling that petitioners lacked a statutory right to a jury trial because the constructive fraud provision contains no mention of such a right and 28 U. S. C. § 1411 affords jury trials only in personal injury or wrongful death suits, and that the Seventh Amendment supplied no right because fraudulent conveyance actions are equitable in nature and bankruptcy proceedings are inherently equitable. The Supreme Court granted certiorari to decide whether petitioners were entitled to a jury trial, 486 U. S. 1054 (1988), and now reverses.
View caseLance Lee, a former executive branch official, challenges the constitutionality of an independent counsel appointed by a special court to investigate executive misconduct. The counsel exercises prosecutorial powers but serves for a limited term. The arrangement is upheld because the tribunal performs a narrow function incidental to Congress's power to structure the executive branch.
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View caseLucas Lee, a pesticide manufacturer, contests an administrative determination that its product registration must include additional safety data. Congress assigned the dispute to a specialized tribunal whose members serve fixed terms. The tribunal resolves the claim as part of a comprehensive federal regulatory program. The assignment is constitutional because the matter is closely integrated with a public-rights scheme created by statute.
Following the 1978 amendments to the Federal Insecticide, Fungicide, and Rodenticide Act, the Environmental Protection Agency gained authority to consider data submitted by one registrant to support the registration of pesticides by follow-on applicants, provided the applicant offers compensation to the original data submitter. If the parties fail to agree on the amount of compensation, either may initiate binding arbitration, and the arbitrator's findings are final except for review based on fraud, misrepresentation, or other misconduct. Appellees are thirteen large firms that had submitted research data to the EPA for pesticide registrations. After the 1978 amendments took effect, the firms filed suit in the Southern District of New York challenging the data-consideration and compensation provisions on constitutional grounds, later amending the complaint to include an Article III claim regarding the arbitration mechanism. The district court granted appellees' motion for summary judgment on their Article III claims. The District Court, rather than striking down the statutory limitation on judicial review, enjoined the entire FIFRA data use and compensation scheme. The Supreme Court vacated that judgment and remanded the case for reconsideration in light of its decision in Ruckelshaus v. Monsanto Co. On remand in this case, appellees amended their complaint to reflect that EPA had, in fact, considered their data in support of other registration applications. The amended complaint also alleged that data submitted by appellee Stauffer Chemical Company had been used in connection with registrations by PPG Industries, Inc., and Drexel Chemical Company. Stauffer had invoked the arbitration provisions of § 3(c)(1)(D)(ii) against PPG, and appellees entered in evidence the award of the arbitration panel, handed down on June 28, 1983. The district court reinstated its prior judgment enjoining the operation of the data-consideration provisions as violative of Article III. The Supreme Court noted probable jurisdiction on EPA's direct appeal.
View caseLegislative courts are created by Congress under Article I and their judges lack life tenure and salary protection. Article III courts are established under Article III and their judges receive those protections. Legislative courts may combine administrative and adjudicative roles within federal regulatory programs.
Congress may assign disputes involving public rights or matters closely tied to federal regulatory schemes. It may not assign wholesale traditional private-rights actions such as state-law contract claims between private parties. The assignment must leave ultimate judicial power in Article III courts where required.
No. Legislative courts may issue binding judgments in matters within their assigned jurisdiction. Their decisions remain subject to appropriate Article III review when the Constitution requires it. The absence of life tenure does not convert their rulings into mere advice.
A legislative court may not enter final judgment on state-law contract claims between private parties even when they arise in bankruptcy. Such claims are the type traditionally resolved by Article III courts. A broad grant of final authority over them violates Article III.