Since the beginning of the New Deal era, regulations promulgated by administrative agencies have formed an ever increasing part of American law. In additon, some agencies have been authorized to adjudicate disputes involving private parties. In Crowell v. Benson, the Supreme Court upheld the right of the U.S. Employees' Compensation Commission to decide an employee's workmen's compensation claim against an employer, finding that such a proceeding did not violate the Article III requirement that the judicial power of the United States be vested in judges appointed to serve during good behavior. Crucial to the Court's holding was the availability of appellate review in the federal courts of the agency's decision. The decision set a precedent for the constitutional legitimacy of administrative adjudication.
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