Crowell v. Benson

Supreme Court of the United States · 1932 · Federal Courts

285 U.S. 22 (1932)

Updated August 1, 2026

Federal Courtsnon-Article III adjudicationArticle IIIadmiraltymaritime jurisdictionadministrative adjudicationprivate rightsjurisdictional facts

Facts

A deputy commissioner awarded compensation to Knudsen against Benson under the Longshoremen's and Harbor Workers' Compensation Act based on findings that Knudsen was injured while employed by Benson and while performing service on navigable waters of the United States. Benson challenged the award, alleging that Knudsen was not his employee and that the claim was therefore not within the deputy commissioner's jurisdiction. The district court heard evidence anew and found that no employment relationship existed. The constitutional challenge focused on whether Congress could make the deputy commissioner's factual determinations final in this setting.

Issue

May Congress, consistent with Article III and due process, make a deputy commissioner's findings of fact final under the Longshoremen's and Harbor Workers' Compensation Act? More specifically, must a federal court independently determine the fundamental facts of whether the injury occurred on navigable waters and whether the relation of master and servant existed?

Rule

Under the Longshoremen's and Harbor Workers' Compensation Act, ordinary findings of fact by the deputy commissioner concerning compensation claims within the Act's coverage may be made final if supported by evidence and reached with notice and hearing. But fundamental or jurisdictional facts that are conditions precedent to the statute's valid operation—specifically, the locality of the injury on navigable waters and the existence of the master-servant relationship—must remain subject to independent judicial determination by an Article III court on its own record.

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A deputy commissioner in Miami awards compensation under a federal maritime compensation statute to Leo Marin against Gulf Pier Services, finding that Leo was injured while employed by Gulf Pier Services on navigable waters. In federal district court, the company introduces new testimony that Leo was actually hired and supervised by a separate stevedoring firm.

How should the district court treat the deputy commissioner's finding on the employment relationship?

Explanation. Under the majority's rule, the existence of the master-servant relationship is a fundamental or jurisdictional fact. Because that fact is a condition precedent to the statute's operation and to Congress's constitutional power to impose liability without fault, an Article III court must determine it independently on its own record in the injunction proceeding.