Atlas Roofing Co. v. Occupational Safety and Health Review Commission
United States Supreme Court
430 U.S. 442 (1977)
Concerned that state courts were not adequately protecting workplace safety, Congress passed the Occupational Safety and Health Act of 1970, empowering the Secretary of Labor to inspect workplaces and fine employers up to $10,000 for violations. Employers could contest fines in a hearing before an administrative law judge, with the burden on the government, and could appeal an adverse decision either to the full Occupational Safety and Health Review Commission or, if the Commission declined review, directly to a federal court. Atlas Roofing challenged the constitutionality of adjudicating these fines without a jury.
Whether Congress may create a cause of action adjudicated by a non-jury fact-finder without violating the Seventh Amendment.