Paramino Lumber Co. v. Marshall

Summary

The Supreme Court considered whether a private act of Congress authorizing reconsideration of a final compensation award under the Longshoremen's and Harbor Workers' Compensation Act violated the Fifth Amendment's Due Process Clause. The Court upheld the legislation as a curative measure addressing an administrative defect and held that it did not improperly create a new obligation or invade the judicial function. The Court also rejected an equal-protection challenge based on reading the Fourteenth Amendment into the Fifth Amendment.

Holdings

1. The private Act of Congress directing administrative review of Clark's final compensation award does not violate the Fifth Amendment's Due Process Clause because it is a curative measure addressing an administrative defect and does not set aside a judgment, create a new right of action, or direct entry of a particular award.
2. The private Act does not violate the Fifth Amendment on the theory that equal protection principles are incorporated into the Due Process Clause.
3. The private Act does not constitute an unconstitutional exercise by Congress of the judicial function.

Questions Presented

1. Whether the Fifth Amendment's Due Process Clause prohibits a private Act of Congress from directing review of a final compensation order after the statutory period for review has expired.
2. Whether the private Act violates equal protection principles allegedly incorporated into the Fifth Amendment's Due Process Clause.
3. Whether the private Act unconstitutionally exercises the judicial function by directing administrative review of the prior compensation award.

Disposition

affirmed