Northern Pipeline Construction Co. v. Marathon Pipe Line Co.



Facts: Congress creates bankruptcy courts which appear to be part of the executive branch. They're almost like Article III courts, except they can't enjoin other courts, and the judges are appointed for terms. There's a breach of contract suit between the parties, and one files for banrupcy. The other contends that this is an impermissible usurpation of Article III powers.

Posture: Suit for damages; motion to dismiss for want of jurisdiction. Bankruptcy judge denies the motion. Appeal.

Issue: Does the Bankruptcy Act of 1982 violate Article III's command that the judicial power be vested in courts whose judges enjoy the protections specified in that article?

Holding: Yes. The proceedings are stayed so that congress can reorganize things.

Rule: Article III bars congress from vesting the essential attributes of the judicial power in an adjunct budy.

Reasoning: If congress creates a right, it can create a procedure by which it can be vindicated, but this is not that. Here, we're not talking about the ajudication of state-created rights, but the restructuring of debtor-creditor relations; this is the sort of dispute-resolving that's at the core of the judicial function. The judicial power of the US must be vested in an independent judiciary. Because of their various attributes, it's clear that the bankruptcy judges aren't Article III judges.

Dicta: White (dissenting): this isn't really a usurpation of federal judicial power, since without a federal bankruptcy court, these would pretty much be state matters. We should defer to congress's judgment.