Workers’ Compensation · Primary-source case analysis

Crowell v. Benson: Compensation Factfinding Could Be Administrative, With Judicial Limits

By Aneeta Mishra and Timothy Chan

Published May 24, 2026

Crowell v. Benson arose from a federal compensation award to an injured waterfront worker and tested how adjudicatory authority could be divided between an agency and an Article III court.

Congress created an administrative compensation process

A deputy commissioner received evidence and entered an award under the Longshoremen’s and Harbor Workers’ Compensation Act, subject to judicial proceedings to suspend or set it aside.

Ordinary facts could be resolved administratively

The Court permitted final administrative findings on routine questions arising within the statutory scheme when supported under the governing review framework.

Constitutional and jurisdictional facts received independent judicial attention

Questions essential to the statute’s constitutional application—including whether the injury occurred on navigable waters and whether the employment relationship existed—could not be insulated completely from judicial determination.

The challenged award was set aside on the developed record

The Court sustained the statutory structure but held that the district court could decide the jurisdictional employment issue rather than treat the agency finding as conclusive.

Key takeaways

• Separate ordinary merits facts from jurisdictional predicates.
• Build the administrative record even when judicial review is expected.
• Identify the review standard for each issue.
• Preserve constitutional objections with precise factual foundations.