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Crowell v. Benson

United States Supreme Court
285 U.S. 22 (1932)


Knudsen was a longshoreman who was injured while working on a boat for Benson. Knudsen brought a workers’ compensation claim against Benson under the Longshoremen’s and Harbor Workers’ Compensation Act, 33 U.S.C. §§ 901-950 (the Act). Crowell, the workers’ compensation judge, ruled in favor of Knudsen. Benson (plaintiff) then filed suit in federal district court against Crowell (defendant), alleging the workers’ compensation court did not have jurisdiction, because Knudsen was not employed by Benson at the time of the injury. Benson amended his complaint to allege that the Act was unconstitutional. The district court denied both parties’ motions to dismiss and granted a de novo hearing on the facts and the law, concluding that the Act would be invalid if it did not allow a new hearing. The case was then transferred to the admiralty docket, and both parties presented evidence regarding the issue of employment. The district court concluded that Knudsen was not employed by Benson and enjoined enforcement of the workers’ compensation award. The court of appeals affirmed the district court ruling, and the United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Hughes, C.J.)

Dissent (Brandeis, J.)

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