Atlas Roofing Co., Inc. v. Occupational Safety and Health Review Commission

Supreme Court of the United States · 1977 · Administrative Law

Administrative LawCivil ProcedureSeventh AmendmentAdministrative AdjudicationPublic RightsSeventh Amendmentpublic rightsadministrative agency

Facts

Congress enacted OSHA after finding existing state statutory and common-law remedies inadequate to protect workers from unsafe working conditions. The Act created a new statutory duty regarding workplace safety and authorized administrative proceedings in which the Government could obtain abatement orders and civil penalties without a jury trial. Atlas was cited for a serious roof-opening-cover violation and assessed a $600 penalty, while Irey was cited for a willful trenching violation and ultimately assessed a $5,000 penalty. In each case, the employers contested the citations, received administrative hearings, and argued that the Seventh Amendment entitled them to a jury on the facts underlying the violations.

Issue

Whether the Seventh Amendment prohibits Congress from creating a new statutory cause of action for civil penalties enforceable by the Government in an administrative agency without a jury trial. More specifically, whether Congress may assign adjudication of OSHA violations and penalties to the Occupational Safety and Health Review Commission.

Rule

When Congress creates new statutory public rights and the Government sues in its sovereign capacity to enforce those rights under a valid federal statute, the Seventh Amendment does not prohibit Congress from assigning factfinding and initial adjudication to an administrative forum with which a jury would be incompatible. The Seventh Amendment preserves jury trial in suits at common law, but it does not bar Congress from creating new rights and remedies and placing their enforcement outside the regular courts of law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress enacts the Chemical Storage Safety Act after finding state negligence suits inadequate to prevent industrial leaks. The Act creates a new federal duty for warehouse operators in Ohio to maintain specified containment systems, authorizes the United States Safety Board to seek abatement orders and civil penalties in an agency hearing, and provides court of appeals review for substantial evidence. After an inspection in Cleveland, the Board charges Lakefront Drum Depot and seeks a $12,000 civil penalty.

Lakefront argues the Seventh Amendment entitles it to a jury because the government is seeking money. How should a court rule?

Explanation. The majority held that when Congress creates new statutory public rights and authorizes the government to enforce them in its sovereign capacity, the Seventh Amendment does not bar initial factfinding and adjudication in an administrative forum incompatible with jury trial. The presence of a civil penalty does not itself convert the proceeding into a jury-required suit at common law. (Derived from Atlas Roofing Co., Inc. v. Occupational Safety and Health Review Commission (1977).)