FACTS: Respondents filed complaints against petitioner pursuant to Commodity Futures Trading Commission's (CFTC) reparations jurisdiction. Petitioner had filed a diversity action in federal district court, but it voluntarily dismissed the action and presented its claim by way of a counterclaim in the reparations proceeding. The administrative law judge (ALJ) in the reparations proceeding ruled in favor of petitioner for both claims. Respondents challenged CFTC's authority to adjudicate petitioner's counterclaim. The court of appeals ordered dismissal of petitioner's counterclaim. The CFTC filed a petition for certiorari, and it was granted. The Court found that in examining the Commodity Exchange Act, 7 U.S.C.S. § 1 et seq., Congress plainly intended CFTC to decide counterclaims asserted in reparations actions. The court held that any intrusion by the CFTC on the judicial branch was de minimis. The court held that if it were not to permit CFTC the authority to adjudicate common law counterclaims at the election of the parties, it would defeat the purpose of the legislation to furnish a prompt and inexpensive method for dealing with those questions suited to determination by CFTC.
CONCLUSION: The court reversed the district court decision and remanded for further proceedings consistent with the opinion. The court found that the Commodity Exchange Act empowered the Commodity Futures Trading Commission to entertain state law counterclaims in reparations proceedings and that such grant of authority did not violate U.S. Const. art. III.
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?