Crowell v. Benson, 285 U.S. 22 (1932) is the first United States Supreme Court decision that approved the adjudication of private rights by an administrative agency, not an Article III court. The Court held that the United States Employees' Compensation Commission satisfied Fifth Amendment Due Process and the requirements of Article III with its court-like procedures and because it invests the final power of decision in Article III courts.

The decision

Justice Hughes stated the main question in the case to be "whether 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 facts upon which the enforcement of the constitutional rights of the citizen depend."

The dissent

Justice Brandeis argued that "[t]o permit a content de novo in the district court of an issue tried, or triable, before the deputy commission will . . . gravely hamper the effective administration" of an Act.