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Crowell v. Benson - 285 U.S. 22, 52 S. Ct. 285 (1932)

Rule:

When the validity of an act of Congress is drawn in question, and even if a serious doubt of constitutionality is raised, it is a cardinal principle that a court will first ascertain whether a construction of the statute is fairly possible by which the question may be avoided.

Facts:

This suit was brought in the District Court to enjoin the enforcement of an award made by petitioner Crowell, as deputy commissioner of the United States Employees' Compensation Commission, in favor of the petitioner Knudsen and against the respondent Benson. The award was made under the Longshoremen's and Harbor Workers' Compensation Act (Act of March 4, 1927, c. 509, 44 Stat. 1424; U. S. C. Tit. 33, §§ 901-950) and rested upon  [*37]  the finding of the deputy commissioner that Knudsen was injured while in the employ of Benson and performing service upon the navigable waters of the United States. The complainant alleged that the award was contrary to law for the reason that Knudsen was not at the time of his injury an employee of the complainant and his claim was not 'within the jurisdiction' of the deputy commissioner. An amended complaint charged that the Act was unconstitutional upon the grounds that it violated the due process clause of the Fifth Amendment, the provision of the Seventh Amendment as to trial by jury, that of the Fourth Amendment as to unreasonable search and seizure, and the provisions of Article III with respect to the judicial power of the United States. 

Issue:

May federal judiciary courts make de novo rulings on jurisdictional facts even if Congress has given an administrative court the power to make factual findings?

Answer:

Yes.

Conclusion:

The district court found that respondent was not liable to petitioner for injuries under the Longshoremen's and Harbor Workers' Compensation Act (Act), 33 U.S.C.S. §§ 901-950, because petitioner was not an employee as required under the Act. Although the United States Employees' Compensation Commission (Commission) determined that respondent was liable, the district court reversed. The court reviewed the validity of the Act in consideration to the provisions defining substantive rights and its procedural requirements. The court determined that there was no room for objection on constitutional grounds to the creation of the substantial rights. Under the Act, the fundamental rights in question gave the court deference over the administrative action of the Commission. The district court did not err in permitting a trial de novo on the issue of employment.

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