285 U.S. 22 (1932)
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.1 The evidence introduced before the deputy commissioner was directed largely to the employment issue and was conflicting.2
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.3 Benson then brought suit in the United States District Court to enjoin enforcement of the award.4 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.5
An amended complaint further challenged the constitutionality of the Act on multiple grounds.6 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.7 The District Judge denied motions to dismiss and granted a hearing de novo upon the facts and the law.8
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.9 The decree was affirmed by the Circuit Court of Appeals, and this Court granted writs of certiorari.10
Whether the Longshoremen's and Harbor Workers' Compensation Act violates the due process clause of the Fifth Amendment through its provisions for administrative determination of questions of fact?11
No. The Act supplies written notice to the employer, a public hearing at which both parties may present evidence, and a stenographic record of proceedings.15 The deputy commissioner received conflicting evidence on the employment issue before finding that Knudsen was in Benson's employ at the time of injury.16 The District Court conducted a de novo hearing only after the compensation order issued and only on the separate question of the employment relation.17
The Act does not violate the due process clause of the Fifth Amendment.18
Related opinions on this issue
Joined by Justice Stone And Justice Roberts
Justice Brandeis dissented because Congress did not authorize a trial de novo on any issue.19 He maintained that due process does not require one for the employment question. Administrative findings supported by evidence are conclusive in workmen's compensation schemes just as they are for other routine facts.20
The safeguards Congress placed around deputy commissioner proceedings would lose all meaning if those proceedings served merely as a preliminary inquiry before a full contest in court.21 Brandeis concluded that the decree should be reversed because the Longshoremen's Act places all factual issues on the same footing for review.22
Whether the Longshoremen's and Harbor Workers' Compensation Act is consistent with Article III of the Constitution in authorizing an administrative agency to make final determinations of facts including those described as jurisdictional such as the existence of an employer-employee relationship and the occurrence of injury upon navigable waters?23
Article III preserves the judicial power.24 It requires independent judicial determination of jurisdictional facts upon which Congress's constitutional authority to legislate depends.25 Congress may assign ordinary fact-finding in private-right cases to administrative agencies.26 Those determinations receive appropriate judicial review.27
Yes. The Act is construed to allow the District Court to determine de novo the existence of the employer-employee relationship.28 The court did so by receiving evidence from both parties at a hearing on the admiralty docket and finding that Knudsen was not in the employ of Benson.29 This construction preserves judicial authority over the facts that condition the statute's constitutional application.30
The Act is consistent with Article III of the Constitution when construed to permit de novo judicial review of jurisdictional facts.31
Related opinions on this issue
Joined by Justice Stone And Justice Roberts
Justice Brandeis argued that the existence of the employer-employee relation is a quasi-jurisdictional fact that the deputy commissioner had full authority to decide.32 The statute places all factual issues on the same footing for review.33 Requiring de novo trials on this issue would impair the administrative scheme Congress created to handle maritime compensation claims efficiently.34
Brandeis noted that the deputy commissioner is a fact-finding tribunal of first instance whose conclusions on employment are open to reexamination in court only on questions of law.35 He concluded that the judgment below should be reversed and the case remanded for decision upon the record made before the deputy commissioner.36
Whether the Longshoremen's and Harbor Workers' Compensation Act violates the Seventh Amendment by denying a right to trial by jury?37
As the claims which are subject to the provisions of the Act are governed by the maritime law as established by the Congress and are within the admiralty jurisdiction, the objection raised by the respondent's pleading as to the right to a trial by jury under the Seventh Amendment is unavailing.38
No. The claims subject to the Act arise from injuries occurring upon the navigable waters of the United States.39 Knudsen's injury claim therefore fell within maritime law and admiralty jurisdiction.40 The District Court properly transferred the case to the admiralty docket without providing a jury.41
The Act does not violate the Seventh Amendment.42
Whether the Longshoremen's and Harbor Workers' Compensation Act violates the Fourth Amendment through its provisions relating to searches and seizures?43
The objection under the Fourth Amendment is neither explained nor urged.44
No. The amended complaint raised a Fourth Amendment objection.45 That objection was neither explained nor urged in the proceedings before the Court.46 The respondent presented no argument or evidence showing how the Act's procedural provisions amounted to an unreasonable search or seizure.47 The objection therefore provided no basis for invalidating the statute.48
The Act does not violate the Fourth Amendment.49