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Commodity Futures Trading Commission v. Schor | 478 U.S. 833 (1986)
During the past century, Congress has often delegated to federal agencies authority to adjudicate not only private disputes concerning rights created by the statute over which the agency has jurisdiction, but also related state-law claims. Does such delegation violate Article III of the Constitution, which vests federal judicial power in federal courts? The United States Supreme Court addressed this issue in Commodity Futures Trading Commission versus Schor.
On behalf of himself and his company, William Schor filed complaints with the Commodity Futures Trading Commission against Conti Commodity Services, a commodity futures broker. Schor claimed that his negative account balance with Conti had resulted from Conti’s violations of the Commodity Exchange Act and sought reparations for his losses. Conti simultaneously filed a diversity lawsuit in federal district court, raising a state-law claim in the amount of Schor’s negative balance. Schor moved to dismiss or stay the district court proceedings based on his pending administrative proceeding before the commission. Schor contended that Conti could raise its state-law counterclaim in that proceeding if it wished. Conti voluntarily dismissed the federal court case and filed its counterclaim in the administrative proceeding.
An administrative law judge ruled against Schor on his statutory claim and for Conti on its counterclaim. Only after that ruling did Schor challenge the commission’s legal authority to adjudicate Conti’s state-law counterclaim. The administrative law judge rejected Schor’s argument, and the Commission refused to reverse the administrative law judge’s decision. Schor petitioned the United States Court of Appeals for the District of Columbia Circuit to review the commission’s decision. The D.C. Circuit held that Conti’s counterclaim should be dismissed on the ground that the commission lacked authority to adjudicate a state-law counterclaim.
The commission successfully petitioned the United States Supreme Court to review Schor’s case.
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