Case Identification
Case name: Northern Pipeline Construction Co. v. Marathon Pipe Line Co.
Court: Supreme Court of the United States
Jurisdiction: Federal
Year: 1982
Citation: 458 U.S. 50
Claim Presented
Marathon Pipe Line Company challenged the constitutionality of the Bankruptcy Act of 1978, which vested bankruptcy judges with jurisdiction to adjudicate state law contract claims between private parties. Marathon contended that assigning such adjudicatory authority to non-Article III judges violated Article III of the Constitution.
Authority Cited
Article III of the United States Constitution
The Bankruptcy Act of 1978, 28 U.S.C. § 1471
The Court examined whether the grant of jurisdiction to bankruptcy courts—whose judges lacked life tenure and salary protection—exceeded constitutional limitations on the assignment of the judicial power of the United States to non-Article III tribunals.
Court’s Analysis
The plurality opinion concluded that the Bankruptcy Act of 1978 impermissibly conferred Article III judicial power upon judges not possessing the constitutional protections of life tenure and protection against salary diminution. The Court examined the scope of adjudicatory power granted to bankruptcy judges under the Act, which extended to “all civil proceedings arising under title 11 or arising in or related to cases under title 11.”
The plurality determined that the state law contract claim at issue was not a matter that fell within recognized exceptions to Article III requirements. The Court identified three categories of cases in which Congress has created non-Article III tribunals: territorial courts, courts-martial, and adjudication of public rights. The plurality found that the private contract dispute before the bankruptcy court did not fit within these established exceptions.
The Court stated that the bankruptcy judges’ exercise of jurisdiction over traditional state law claims between private parties, without the structural protections of Article III, could not be sustained under existing precedent. The plurality emphasized that the judicial power to adjudicate such claims is a core function reserved to Article III courts.
Disposition
The statutory provision was declared unconstitutional. The judgment of the district court holding 28 U.S.C. § 1471 unconstitutional was affirmed.
Procedural Outcome
The 1978 Bankruptcy Act’s jurisdictional grant to bankruptcy courts was invalidated. Congress subsequently enacted revised bankruptcy legislation to conform to constitutional requirements.
Archival Note
This entry documents the judicial record in Northern Pipeline Construction Co. v. Marathon Pipe Line Co. as preserved in the official reports. The decision addressed constitutional limits on the adjudicatory authority of non-Article III courts and clarified the separation of judicial power as reflected in the Court’s disposition.