## Facts

- Congress enacted the Occupational Safety and Health Act of 1970 (OSHA) after finding existing state and common-law remedies inadequate to prevent workplace injuries and deaths.
- OSHA created new statutory duties for employers and authorized federal enforcement through abatement orders and civil penalties for maintaining unsafe working conditions.
- When an employer contests a citation, penalty, or abatement order, the dispute is tried in an evidentiary hearing before an Administrative Law Judge (ALJ) of the Occupational Safety and Health Review Commission (OSHRC), with possible Commission review.
- On judicial review, a court of appeals treats OSHRC findings of fact as conclusive if supported by substantial evidence.
- If an employer does not pay an assessed penalty, the Secretary of Labor may sue in federal district court to collect, but the violation and amount are not retried.
- Atlas Roofing Co., Inc. and Frank Irey, Jr., Inc. were cited for OSHA safety violations; ALJs upheld the citations and penalties, and OSHRC affirmed.
- The Fifth and Third Circuits affirmed the Commission’s final orders, rejecting the employers’ Seventh Amendment jury-trial challenges.

## Issues

1. Whether the Seventh Amendment requires a jury trial when the federal government seeks OSHA civil penalties and abatement orders for violations of federal workplace-safety standards.
2. Whether Congress may assign adjudication and factfinding for these statutory enforcement actions to an administrative tribunal as “public rights” without triggering the jury-trial guarantee.

## Decision

- The Supreme Court affirmed the courts of appeals.
- Congress may assign adjudication of newly created statutory public rights, including the imposition of civil penalties under OSHA, to an administrative agency without violating the Seventh Amendment.
- The Seventh Amendment does not bar Congress from placing initial factfinding and adjudication of such regulatory enforcement actions in an administrative forum, even when monetary penalties may be imposed.

## Legal Principles

- The Seventh Amendment preserves jury trial for “suits at common law,” but does not require juries when Congress creates new public rights and commits their enforcement to administrative adjudication.
- Civil penalties imposed as part of a comprehensive federal regulatory program may be treated as public-rights enforcement rather than as traditional private damages actions.
- Congress may design administrative enforcement systems that include ALJ hearings, agency review, and limited Article III judicial review (including substantial-evidence review of factfinding) without providing a jury trial.

## Conclusion

OSHA’s scheme for agency adjudication of workplace-safety violations, including civil penalties and abatement orders, is constitutional because it enforces statutory public rights that Congress may assign to administrative tribunals without a Seventh Amendment jury trial.


Atlas Roofing Co. v. Occupational Safety & Health Review Comm'n, 430 U.S. 442 (1977)