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Crowell v. Benson | 285 U.S. 22 (1932)

A longshoreman sought workers’ compensation for an injury, but the parties disputed whether he was an employee. In Crowell versus Benson, the issue before the Supreme Court wasn’t whether the longshoreman was an employee or an independent contractor, but rather, who could make that determination.

J.B. Knudsen tried to obtain compensation under the Longshoremen’s and Harbor Workers’ Compensation Act, which we’ll call the act, for injuries sustained while working for Charles Benson. Letus Crowell, the deputy commissioner of the United States Employees’ Compensation Commission, ruled for Knudsen. Benson then sued Crowell in federal district court, seeking to enjoin enforcement of the award. He argued that Crowell lacked jurisdiction because the act only covered employees, and Knudsen was an independent contractor, not an employee, at the time of the injury. Benson also argued that the act was unconstitutional because it permitted an administrative agency, rather than an Article Three judge, to decide a dispute between two private parties.

The district court granted a de novo hearing and determined that Knudsen wasn’t employed by Benson. It enjoined the enforcement of the award. The Fifth Circuit affirmed, and the Supreme Court granted cert.

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