1	Crowell v. Benson (1932) Mr. Chief Justice HUGHES delivered the opinion of the Court. 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.
2	Administrative Findings The award was made under the Longshoremen's and Harbor Workers' Compensation Act Act of March 4, 1927, and rested upon 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 Kundsen 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.
3	Substantive and Procedural Requirements The question of the validity of the act may be considered in relation to (1) its provisions defining substantive rights and (2) its procedural requirements. First. The act has two limitations that are fundamental. It deals exclusively with compensation in respect of disability or death resulting 'from an injury occurring upon the navigable waters of the United States' if recovery 'through workmen's compensation proceedings may not validly be provided by State law,' and it applies only when the relation of master and servant exists. Section 3.1 'Injury,' within the statute, 'means accidental injury or death arising out of and in the course of employment.
4	Constitutional Ruling on Substantive Grounds In view of federal power to alter and revise the maritime law, there appears to be no room for objection on constitutional grounds to the creation of these rights, unless it can be found in the due process clause of the Fifth Amendment. But it cannot be said that either the classifications of the statute or the extent of the compensation provided are unreasonable
5	Procedural Issues The objections to the procedural requirements of the act relate to the extent of the administrative authority which it confers. The contention under the due process clause of the Fifth Amendment relates to the determination of questions of fact.
6	Questions of Fact Apart from cases involving constitutional rights to be appropriately enforced by proceedings in court, there can be no doubt that the act contemplates that as to questions of fact, arising with respect to injuries to employees within the purview of the act, the findings of the deputy commissioner, supported by evidence and within the scope of his authority, shall be final.
7	Purpose of Legislation Establishing Administrative Agency Adjudication To hold otherwise would be to defeat the obvious purpose of the legislation to furnish a prompt, continuous, expert, and inexpensive method for dealing with a class of questions of fact which are peculiarly suited to examination and determination by an administrative agency specially assigned to that task.
8	Public v Private Rights As to determinations of fact, the distinction is at once apparent between cases of private right and those which arise between the government and persons subject to its authority in connection with the performance of the constitutional functions of the executive or legislative departments.
9	Nature of Hearing The statute provides for notice and hearing, and an award made without proper notice, or suitable opportu- nity to be heard, may be attacked and set aside as without validity. The objection is made that, as the deputy commissioner is authorized to prosecute such inquiries as he may consider necessary, the award may be based wholly or partly upon an ex parte investigation and upon unknown sources of information, and that the hearing may be merely a formality.
10	Hearing Requirement The statute, however, contemplates a public hearing, and regulations are to require 'a record of the hearings and other proceedings before the deputy commissioners.'
11	Who Can Decide Private Rights? The present case does not fall within the categories just described, but is one of private right, that is, of the liability of one individual to another under the law as defined. But, in cases of that sort, there is no requirement that, in order to maintain the essential attributes of the judicial power, all determinations of fact in constitutional courts shall be made by judges. On the common-law side of the federal courts, the aid of juries is not only deemed appropriate but is required by the Constitution itself. In cases of equity and admiralty, it is historic practice to call to the assistance of the courts, without the consent of the parties, masters, and commissioners or assessors, to pass upon certain classes of questions, as, for example, to take and state an account or to find the amount of damages
12	Judicial Review of Facts It may also be noted that, while on an appeal in admiralty cases 'the facts, as well as the law, would be subjected to review and retrial,' this Court has recognized the power of the Congress 'to limit the effect of an appeal to a review of the law as applicable to facts finally determined below.'
13	Has Congress Exceeded Its Authority? The statute has a limited application. The act itself, where it applies, establishes the measure [intelligible principle]of the employer's liability. For the purposes stated, we are unable to find any constitutional obstacle to the action of the Congress in availing itself of a method shown by experience to be essential in order to apply its standards to the thousands of cases involved.
14	Jurisdictional Facts What has been said thus far relates to the determination of claims of employees within the purview of the act. A different question is presented where the determinations of fact are fundamental or jurisdictional, in the sense that their existence is a condition precedent to the operation of the statutory scheme.
15	Review of Jurisdictional Facts In amending and revising the maritime law, the Congress cannot reach beyond the constitutional limits which are inherent in the admiralty and maritime jurisdiction Unless the injuries to which the act relates occur upon the navigable waters of the United States, they fall outside that jurisdiction.
16	Courts Review Jurisdictional Facts In relation to these basic facts, the question is not the ordinary one as to the propriety of provision for administrative determinations. Nor have we simply the question of due process in relation to notice and hearing. It is rather a question of the appropriate maintenance of the federal judicial power in requiring the observance of constitutional restrictions. It is the question whether the Congress may substitute for constitutional courts, in which the judicial power of the United States is vested, an administrative agency-in this instance a single deputy commissioner-for the final determination of the existence of the facts upon which the enforcement of the constitutional rights of the citizen depend.
17	Constitutional Rights In cases brought to enforce constitutional rights, the judicial power of the United States necessarily extends to the independent determination of all questions, both of fact and law, necessary to the performance of that supreme function. The case of confiscation is illustrative, the ultimate conclusion almost invariably depending upon the decisions of questions of fact.
18	Article III Court Jurisdiction to Review Jurisdictional Facts In the present instance, the argument that the Congress has constituted the deputy commissioner a fact-finding tribunal is unavailing, as the contention makes the untenable assumption that the constitutional courts may be deprived in all cases of the determination of facts upon evidence even though a constitutional right may be involved.
19	Trial De Novo Assuming that the federal court may determine for itself the existence of these fundamental or jurisdictional facts, we come to the question, Upon what record is the determination to be made? A trial de novo on the issue of employment is appropriate in this case.