Atlas Roofing v. OSHA: Agencies May Adjudicate Their Own Civil Penalties

The Supreme Court unanimously upheld OSHA's authority to impose civil penalties through its internal administrative proceedings without a jury trial, ruling that Congress may create new statutory rights and assign their adjudication to agencies without triggering the Seventh Amendment. The Court held that when Congress creates a new public right — such as a workplace safety violation — as opposed to vindicating a private common-law right, no jury trial is required. This "public rights" exception enabled the modern administrative enforcement apparatus across OSHA, SEC, FCC, FTC, and EPA for nearly five decades.