JUSTICE O'CONNOR delivered the opinion of the Court.
This case requires the Court to revisit the data-consideration provision of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 61 Stat. 163, as amended, 7 U.S.C. § 136 et seq., which was considered last Term in Ruckelshaus v. Monsanto Co., 467 U. S. 986 (1984). Monsanto examined whether FIFRA's data-consideration provision effects an uncompensated taking in violation of the Fifth Amendment. In this case, we address whether Article III of the Constitution prohibits Congress from selecting binding arbitration with only limited judicial review as the mechanism for resolving disputes among participants in FIFRA's pesticide registration scheme. We conclude it does not, and reverse the judgment below.
I
The Court's opinion in Monsanto details the development of FIFRA from the licensing and labeling statute enacted in 1947 to the comprehensive regulatory statute of the present. This case, like Monsanto, concerns the most recent amendment to FIFRA, the Federal Pesticide Act of 1978, 92 Stat. 819 (1978 Act), which sought to correct problems created by the Federal Environmental Pesticide Control Act of 1972, 86 Stat. 973 (1972 Act), itself a major revision of prior law. See Ruckelshaus v. Monsanto Co., supra, at 467 U. S. 991 -992.
A
As a precondition for registration of a pesticide, manufacturers must submit research data to the Environmental Protection Agency (EPA) concerning the product's health, safety, and environmental effects. The 1972 Act established data-sharing provisions intended to streamline pesticide registration procedures, increase competition, and avoid unnecessary duplication of data-generation costs. S.Rep. No. 92-838, pp. 72-73 (1972) (1972 S.Rep.). Some evidence suggests that, before 1972, data submitted by one registrant had
as a matter of practice but without statutory authority, been considered by the Administrator to support the registration of the same or a similar product by another registrant.
Ruckelshaus v. Monsanto Co., supra, at 467 U. S. 1009, n. 14. Such registrations were colloquially known as "me too" or "follow-on" registrations. Section 3(c)(1)(D) of the 1972 Act provided statutory authority for the use of previously submitted data, as well as a scheme for sharing the costs of data generation.
In effect, the provision instituted a mandatory data-licensing scheme. The amount of compensation was to be negotiated by the parties, or, in the event negotiations failed, was to be determined by the EPA, subject to judicial review upon instigation of the original data submitter. The scope of the 1972 data-consideration provision, however, was limited, for any data designated as 'trade secrets or commercial or financial information'… could not be considered at all by EPA to support another registration unless the original submitter consented.
Ruckelshaus v. Monsanto Co., supra, at 467 U. S. 992 -993.
Congress enacted the original data-compensation provision in 1972 because it believed "recognizing a limited proprietary interest" in data submitted to support pesticide registrations would provide an added incentive beyond statutory patent protection for research and development of new pesticides. H.R.Rep. No. 95-663, pp. 17-18 (1977); S.Rep. No. 95334, pp. 7, 34-40 (1977) (1977 S.Rep.). The data submitters, however, contended that basic health, safety, and environmental data essential to registration of a competing pesticide qualified for protection as a trade secret. With EPA bogged down in cataloging data and the pesticide industry embroiled in litigation over what types of data could legitimately be designated "trade secrets," new pesticide registrations "ground to a virtual halt." Id. at 3.
The 1978 amendments were a response to the "logjam of litigation that resulted from controversies over data compensation and trade secret protection." Ibid. Congress viewed data-sharing as essential to the registration scheme, id. at 7, but concluded EPA must be relieved of the task of valuation because disputes regarding the compensation scheme had, "for all practical purposes, tied up their registration process" and "[EPA] lacked the expertise necessary to establish the proper amount of compensation." 123 Cong.Rec. 25709 (1977) (statement of Sen. Leahy, floor manager of S. 1678). Legislators and the Agency agreed that
[d]etermining the amount and terms of such compensation are matters that do not require active government involvement, [and] compensation payable should be determined, to the fullest extent practicable, within the private sector.
Id. at 25710.
Against this background, Congress in 1978 amended § 3(c)(1)(D) and § 10(b) to clarify that the trade secret exemption from the data-consideration provision did not extend to health, safety, and environmental data. In addition, the 1978 amendments granted data submitters a 10-year period of exclusive use for data submitted after September 30, 1978, during which time the data may not be cited without the original submitter's permission. § 3(c)(1)(D)(i).
Regarding compensation for use of data not protected by the 10-year exclusive use provision, the amendment substituted for the EPA Administrator's determination of the appropriate compensation a system of negotiation and binding arbitration to resolve compensation disputes among registrants. Section 3(c)(1)(D)(ii) authorizes EPA to consider data already in its files in support of a new registration, permit, or new use, but "only if the applicant has made an offer to compensate the original data submitter." If the applicant and data submitter fail to agree, either may invoke binding arbitration. The arbitrator's decision is subject to judicial review only for "fraud, misrepresentation, or other misconduct." Ibid. [ Footnote 1 ] The statute contains its own sanctions. Should an applicant or data submitter fail to comply with the scheme, the Administrator is required to cancel the new registration or to consider the data without compensation to the original submitter. The Administrator may also issue orders regarding sale or use of existing pesticide stocks. Ibid.
The concept of retaining statutory compensation but substituting binding arbitration for valuation of data by EPA emerged as a compromise. This approach was developed by representatives of the major chemical manufacturers, who sought to retain the controversial compensation provision, in discussions with industry groups representing follow-on registrants, whose attempts to register pesticides had been roadblocked by litigation since 1972. Hearings on Extending and Amending FIFRA before the Subcommittee on Department Investigations, Oversight, and Research of the House Committee on Agriculture, 95th Cong., 1st Sess., 522-523 (1977) (testimony of Robert Alikonis, General Counsel to Pesticide Formulators Association).
B
Appellees are 13 large firms engaged in the development and marketing of chemicals used to manufacture pesticides. Each has in the past submitted data to EPA in support of registrations of various pesticides. When the 1978 amendments went into effect, these firms were engaged in litigation in the Southern District of New York challenging the constitutionality under Article I and the Fifth Amendment of the provisions authorizing data-sharing and disclosure of data to the public. [ Footnote 2 ] In response to this Court's decision in Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U. S. 50 (1982), appellees amended their complaint to allege that the statutory mechanism of binding arbitration for determining the amount of compensation due them violates Article III of the Constitution. Article III, § 1, provides that "[t]he judicial Power of the United States, shall be vested" in courts whose judges enjoy tenure "during good Behaviour" and compensation that "shall not be diminished during their Continuance in Office." Appellees allege Congress, in FIFRA, transgressed this limitation by allocating to arbitrators the functions of judicial officers and severely limiting review by an Article III court.
The District Court granted appellees' motion for summary judgment on their Article III claims. It found the issues ripe because the "statutory compulsion to seek relief through arbitration" raised a constitutionally sufficient case or controversy. Although troubled by what appeared a "standardless delegation of powers," the District Court did not reach the Article I issue because it held that Article III barred FIFRA's "absolute assignment of [judicial] power" to arbitrators with only limited review by Article III judges. Union Carbide Agricultural Products Co. v. Ruckelshaus, 571 F.Supp. 117, 124 (1983). The District Court, rather than striking down the statutory limitation on judicial review, enjoined the entire FIFRA data use and compensation scheme. App. to Juris. Statement 25a.
Appellant took a direct appeal to this Court pursuant to 28 U. S.C. § 1252. We vacated the judgment of the District Court and remanded for reconsideration in light of our supervening decision in Ruckelshaus v. Monsanto Co., 467 U. S. 986 (1984). Ruckelshaus v. Union Carbide Agricultural Products Co., 468 U.S. 1201 (1984). In Monsanto, we ruled that FIFRA's data-consideration provisions may be deemed a "public use" even though the most direct beneficiaries of the regulatory scheme will be the later applicants. 467 U.S. at 467 U. S. 1014. Insofar as FIFRA authorizes the Administrator to consider trade secrets submitted during the period between 1972 and 1978, a period during which the registrant entertained a reasonable, investment-backed expectation that its trade secret data would be held confidential, we held it effects a taking. But the data originator must complete arbitration and, in the event of a shortfall, exhaust its Tucker Act remedies against the United States before it can be ascertained whether it has been deprived of just compensation. The Court distinguished between the "ability to vindicate [the] constitutional right to just compensation" and the "ability to vindicate [the] statutory right to obtain compensation from a subsequent applicant." Id. at 467 U. S. 1019. But we declined to reach Monsanto's Article III claim, explaining:
Monsanto did not allege or establish that it had been injured by actual arbitration under the statute. While the District Court acknowledged that Monsanto had received several offers of compensation from applicants for registration, it did not find that EPA had considered Monsanto's data in considering another application. Further, Monsanto and any subsequent applicant may negotiate and reach agreement concerning an outstanding offer. If they do not reach agreement, then the controversy must go to arbitration. Only after EPA has considered data submitted by Monsanto in evaluating another application and an arbitrator has made an award will Monsanto's claims with respect to the constitutionality of the arbitration scheme become ripe.
Ibid. (citation omitted). On remand in this case, appellees amended their complaint to reflect that EPA had, in fact, considered their data in support of other registration applications. The amended complaint also alleged that data submitted by appellee Stauffer Chemical Company (Stauffer), originator of the chemicals butylate and EPTC, had been used in connection with registrations by PPG Industries, Inc. (PPG), and Drexel Chemical Company of pesticides containing butylate and EPTC as active ingredients. App. 23. The complaint further alleged Stauffer had invoked the arbitration provisions of § 3(c)(1)(D)(ii) against PPG, and appellees entered in evidence the award of the arbitration panel, handed down on June 28, 1983. Id. at 42. Stauffer claimed the arbitrators' award fell far short of the compensation to which it was entitled. [ Footnote 3 ]
In view of these developments, the District Court concluded that
[t]he claims presented by Stauffer challenging the constitutionality of FIFRA § 3(c)(1)(D) are ripe for resolution under the criteria established by the Supreme Court
in Ruckelshaus v. Monsanto Co., supra. The remaining plaintiffs, the District Court held, were aggrieved by the clear threat of compulsion to resort to unconstitutional arbitration. App. to Juris. Statement 1a-4a. The District Court reinstated its prior judgment enjoining the operation of the data-consideration provisions as violative of Article III. EPA again took a direct appeal, and we noted probable jurisdiction. 469 U.S. 1032 (1984). This Court stayed the judgment pending disposition of the appeal.
II
As a threshold matter, we must determine whether appellees' Article III claims demonstrate sufficient ripeness to establish a concrete case or controversy. Regional Rail Reorganization Act Cases, 419 U. S. 102, 419 U. S. 138 -139 (1974). Appellant contends that the District Court erred in addressing these claims because the criteria established in Monsanto for ripeness remained unsatisfied. Appellant argues that only one firm, Stauffer, engaged in arbitration, and it seeks to enforce, rather than challenge, the award. Appellees counter that they are aggrieved by the threat of an unconstitutional arbitration procedure which assigns the valuation of their data to civil arbitrators and prohibits judicial review of the amount of compensation. Stauffer in particular argues that it was doubly injured by the arbitration. Although it claimed a shortfall of some $50 million, it was precluded by § 3(c)(1)(D)(ii) from seeking judicial review of the award against PPG. While seeking to enforce the award should its Article III claim fail, Stauffer has consistently challenged the validity of the entire FIFRA data-consideration scheme both here and in litigation initiated by PPG. See n 3, supra.
We agree that Stauffer has an independent right to adjudication in a constitutionally proper forum. See Glidden Co. v. Zdanok,370 U. S. 530,370 U. S. 533(1962). Although appellees contend and the District Court found that they were injured by the shortfall in the award, it is sufficient, for purposes of a claim under Article III challenging a tribunal's jurisdiction, that the claimant demonstrate it has been or inevitably will be subjected to an exercise of such unconstitutional jurisdiction.See Northern Pipeline Construction Co. v. Marathon Pipe Line Co.,458 U.S. at458 U. S. 56-57,aff'g12 B.R. 946 (Minn.1981) (reversing Bankruptcy Court's denial of pretrial motion to dismiss contract claim).
[A party] may object to proceeding further with [a] lawsuit on the grounds that, if it is to be resolved by an agency of the United States, it may be resolved only by an agency which exercises '[t]he judicial power of the United States' described by Art. III of the Constitution.
458 U.S. at 458 U. S. 89 (opinion concurring in judgment). In contrast to the Taking Clause claim in Monsanto, appellees' Article III injury is not a function of whether the tribunal awards reasonable compensation, but of the tribunal's authority to adjudicate the dispute. Northern Pipeline Construction Co. v. Marathon Pipe Line Co., supra; Glidden Co. v. Zdanok, supra. Thus, appellees state an independent claim under Article III, apart from any monetary injury sustained as a result of the arbitration.
"[R]ipeness is peculiarly a question of timing." Regional Rail Reorganization Act Cases, supra, at 419 U. S. 140. "[I]ts basic rationale is to prevent the courts, through premature adjudication, from entangling themselves in abstract disagreements." Abbott Laboratories v. Gardner, 387 U. S. 136, 387 U. S. 148 (1967). The Article III challenge in Monsanto was, in this sense, premature. Monsanto had not alleged that its data had ever been considered in support of other registrations, much less that Monsanto had failed to reach a negotiated settlement or been forced to resort to an unconstitutional arbitration. In fact, no FIFRA arbitrations had as yet taken place when Monsanto brought its claim. Monsanto's claim thus involved "contingent future events that may not occur as anticipated, or indeed may not occur at all." 13A C. Wright, A. Miller, & E. Cooper, Federal Practice and Procedure § 3532 (1984). By contrast, the FIFRA data-consideration procedures are now in place, and numerous follow-on registrations have been issued. See Brief for Appellees 3, n. 3 (citing Docket Entry No. 132, p. 2). Each of the appellees in this action has alleged as yet uncompensated use of its data. App. 23. Stauffer has engaged in an arbitration lasting many months and consuming 2,700 pages of transcript. There is no doubt that the "effects [of the arbitration scheme] have [been felt by Stauffer] in a concrete way." Abbott Laboratories v. Gardner, 387 U.S. at 387 U. S. 148 -149.
In addition, "the fitness of the issues for judicial decision" and "the hardship to the parties of withholding court consideration" must inform any analysis of ripeness. Id. at 387 U. S. 149. The issue presented in this case is purely legal, and will not be clarified by further factual development. Cf. Pacific Gas & Electric Co. v. State Energy Resources Conservation and Development Comm'n, 461 U. S. 190, 461 U. S. 201 (1983). Doubts about the validity of FIFRA's data-consideration and compensation schemes have plagued the pesticide industry and seriously hampered the effectiveness of FIFRA's reforms of the registration process.
To require the industry to proceed without knowing whether the [arbitration scheme] is valid would impose a palpable and considerable hardship.
Id. at 461 U. S. 201 -202. At a minimum Stauffer, and arguably each appellee whose data have been used pursuant to the challenged scheme, suffers the continuing uncertainty and expense of depending for compensation on a process whose authority is undermined because its constitutionality is in question. See ibid.
'One does not have to await the consummation of threatened injury to obtain preventive relief. If the injury is certainly impending, that is enough.'
Regional Rail Reorganization Act Cases, 419 U.S. at 419 U. S. 143, quoting Pennsylvania v. West Virginia, 262 U. S. 553, 262 U. S. 593 (1923). Nothing would be gained by postponing a decision, and the public interest would be well served by a prompt resolution of the constitutionality of FIFRA's arbitration scheme. Duke Power Co. v. Carolina Environmental Study Group, Inc., 438 U. S. 59, 439 U. S. 82 (1978).
Finally, appellees clearly have standing to contest EPA's issuance of follow-on registrations pursuant to what they contend is an unconstitutional statutory provision. They allege an injury from EPA's unlawful conduct -the injury of being forced to choose between relinquishing any right to compensation from a follow-on registrant or engaging in an unconstitutional adjudication. Allen v. Wright, 468 U. S. 737 (1984). Appellees also allege injury which is likely to be redressed by the relief they request. Ibid. The use, registration, and compensation scheme is integrated in a single subsection that explicitly ties the follow-on registration to the arbitration. See § 3(c)(1)(D)(ii) (EPA "shall deny" or "cancel" follow-on registration if arbitration section is not complied with). It is evident that Congress linked EPA's authority to issue follow-on registrations to the original data submitter's ability to obtain compensation. A decision against the provision's constitutionality, therefore, would support remedies such as striking down the statutory restrictions on judicial review or enjoining EPA from issuing or retaining in force follow-on registrations pursuant to § 3(c)(1)(D)(ii).
III
Appellees contend that Article III bars Congress from requiring arbitration of disputes among registrants concerning compensation under FIFRA without also affording substantial review by tenured judges of the arbitrator's decision. Article III, § 1, establishes a broad policy that federal judicial power shall be vested in courts whose judges enjoy life tenure and fixed compensation. These requirements protect the role of the independent judiciary within the constitutional scheme of tripartite government and assure impartial adjudication in federal courts. United States v. Will, 449 U. S. 200, 449 U. S. 217 -218 (1980); Buckley v. Valeo, 424 U. S. 1, 424 U. S. 122 (1976) (per curiam).
An absolute construction of Article III is not possible in this area of "frequently arcane distinctions and confusing precedents." Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U.S. at 458 U. S. 90 (opinion concurring in judgment).
[N]either this Court nor Congress has read the Constitution as requiring every federal question arising under the federal law… to be tried in an Art. III court before a judge enjoying life tenure and protection against salary reduction.
Palmore v. United States, 411 U. S. 389, 411 U. S. 407 (1973). Instead, the Court has long recognized that Congress is not barred from acting pursuant to its powers under Article I to vest decisionmaking authority in tribunals that lack the attributes of Article III courts. See, e.g., Walters v. National Assn. of Radiation Survivors, ante p. 473 U. S. 305 (Board of Veterans' Appeals); Palmore v. United States, supra, (District of Columbia courts); Crowell v. Benson, 285 U. S. 22 (1932) (Deputy Commissioner of Employees' Compensation Commission); Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856) (Treasury accounting officers). Many matters that involve the application of legal standards to facts and affect private interests are routinely decided by agency action with limited or no review by Article III courts. See, e.g., 5 U.S.C. §§ 701(a)(1), 701(a)(2); Heckler v. Chaney, 470 U. S. 821, 470 U. S. 837 -838 (1985); United States v. Erika, Inc., 456 U. S. 201, 456 U. S. 206 (1982) (no review of Medicare reimbursements); Monaghan, Marbury and the Administrative State, 83 Colum.L.Rev. 1, 18 (1983) (administrative agencies can conclusively adjudicate claims created by the administrative state, by and against private persons); Redish, Legislative Courts, Administrative Agencies, and the Northern Pipeline Decision, 1983 Duke L.J.197 (same).
The Court's most recent pronouncement on the meaning of Article III is Northern Pipeline. A divided Court was unable to agree on the precise scope and nature of Article III's limitations. The Court's holding in that case establishes only that Congress may not vest in a non-Article III court the power to adjudicate, render final judgment, and issue binding orders in a traditional contract action arising under state law, without consent of the litigants, and subject only to ordinary appellate review. 458 U.S. at 458 U. S. 84 (plurality opinion); id. at 458 U. S. 90 -92 (opinion concurring in judgment); id. at 458 U. S. 92 (BURGER, C.J., dissenting).
A
Appellees contend that their claims to compensation under FIFRA are a matter of state law, and thus are encompassed by the holding of Northern Pipeline. We disagree. Any right to compensation from follow-on registrants under § 3 (c)(1)(D)(ii) for EPA's use of data results from FIFRA, and does not depend on or replace a right to such compensation under state law. Cf. Northern Pipeline Construction Co., supra, at 458 U. S. 84 (plurality opinion) (contract claims at issue were matter of state law); Crowell v. Benson, supra, at 285 U. S. 39 -40 (replacing traditional admiralty negligence action with administrative scheme of strict liability). As a matter of state law, property rights in a trade secret are extinguished when a company discloses its trade secret to persons not obligated to protect the confidentiality of the information. See Ruckelshaus v. Monsanto Co., 467 U.S. at 467 U. S. 1002, citing R. Milgrim, Trade Secrets § 1.01[2] (1983). Therefore registrants who submit data with notice of the scheme established by the 1978 amendments, and its qualified protection of trade secrets as defined in § 10, can claim no property interest under state law in data subject to § 3(c)(1)(D)(ii). Ruckelshaus v. Monsanto Co., supra, at 467 U. S. 1005 -1008. Cf. 21 U.S.C. §§ 348(a)(2), 376(a)(1); 21 CFR § 71.15 (1985); 21 CFR § 171.1(h) (1984) (data submitted under Food, Drug, and Cosmetic Act is in public domain, and follow-on registrants need not submit independent data). Nor do individuals who submitted data prior to 1978 have a right to compensation under FIFRA that depends on state law. To be sure, such users might have a claim that the new scheme results in a taking of property interests protected by state law. See 467 U.S. at 467 U. S. 1013 -1014. Compensation for any uncompensated taking is available under the Tucker Act. For purposes of compensation under FIFRA's regulatory scheme, however, it is the "mandatory licensing provision" that creates the relationship between the data submitter and the follow-on registrant, and federal law supplies the rule of decision. Cf. Northern Pipeline Construction Co., supra, at 458 U. S. 90 (opinion concurring in judgment).
Alternatively, appellees contend that FIFRA confers a "private right" to compensation, requiring either Article III adjudication or review by an Article III court sufficient to retain "the essential attributes of the judicial power." Northern Pipeline Construction Co., supra, at 458 U. S. 77, 458 U. S. 85 -86 (plurality opinion). This "private right" argument rests on the distinction between public and private rights drawn by the plurality in Northern Pipeline. The Northern Pipeline plurality construed the Court's prior opinions to permit only three clearly defined exceptions to the rule of Article III adjudication: military tribunals, territorial courts, and decisions involving "public," as opposed to "private," rights. Drawing upon language in Crowell v. Benson, supra, at 285 U. S. 50, the plurality defined "public rights" as
matters arising between the Government and persons subject to its authority in connection with the performance of the constitutional functions of the executive or legislative departments.
458 U.S. at 458 U. S. 67 -68. It identified "private rights" as " the liability of one individual to another under the law as defined.'" Id. at 458 U. S. 69 -70, quoting Crowell v. Benson, 285 U.S. at 285 U. S. 51.
This theory that the public rights/private rights dichotomy of Crowell and Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), provides a bright-line test for determining the requirements of Article III did not command a majority of the Court in Northern Pipeline. Insofar as appellees interpret that case and Crowell as establishing that the right to an Article III forum is absolute unless the Federal Government is a party of record, we cannot agree. Cf. Northern Pipeline Construction Co., 458 U.S. at 458 U. S. 71 (plurality opinion) (noting that discharge in bankruptcy, which adjusts liabilities between individuals, is arguably a public right). But see id. at 458 U. S. 69, n. 23. Nor did a majority of the Court endorse the implication of the private right/public right dichotomy that Article III has no force simply because a dispute is between the Government and an individual. Compare id. at 458 U. S. 68, n. 20, with id. at 458 U. S. 70, n. 23.
B
Chief Justice Hughes, writing for the Court in Crowell, expressly rejected a formalistic or abstract Article III inquiry, stating:
In deciding whether the Congress, in enacting the statute under review, has exceeded the limits of its authority to prescribe procedure… regard must be had, as in other cases where constitutional limits are invoked, not to mere matters of form, but to the substance of what is required.
285 U.S. at 285 U. S. 53 (emphasis added). Crowell held that Congress could replace a seaman's traditional negligence action in admiralty with a statutory scheme of strict liability. In response to practical concerns, Congress rejected adjudication in Article III courts, and instead provided that claims for compensation would be determined in an administrative proceeding by a deputy commissioner appointed by the United States Employees' Compensation Commission. Id. at 285 U. S. 43. "[T]he findings of the deputy commissioner, supported by evidence and within the scope of his authority" were final with respect to injuries to employees within the purview of the statute. Id. at 285 U. S. 46. Although such findings clearly concern obligations among private parties, this fact did not make the scheme invalid under Article III. Instead, after finding that the administrative proceedings satisfied due process, id. at 285 U. S. 45 -48, Crowell concluded that the judicial review afforded by the statute, including review of matters of law, "provides for the appropriate exercise of the judicial function in this class of cases." Id. at 285 U. S. 54.
The enduring lesson of Crowell is that practical attention to substance, rather than doctrinaire reliance on formal categories, should inform application of Article III. Cf. Glidden Co. v. Zdanok, 370 U.S. at 370 U. S. 547 -548. The extent of judicial review afforded by the legislation reviewed in Crowell does not constitute a minimal requirement of Article III without regard to the origin of the right at issue or the concerns guiding the selection by Congress of a particular method for resolving disputes. In assessing the degree of judicial involvement required by Article III in this case, we note that the statute considered in Crowell is different from FIFRA in significant respects. Most importantly, the statute in Crowell displaced a traditional cause of action and affected a preexisting relationship based on a common law contract for hire. Thus, it clearly fell within the range of matters reserved to Article III courts under the holding of Northern Pipeline. See 458 U.S. at 458 U. S. 70 -71, and n. 25 (plurality opinion) (noting that matters subject to a "suit at common law or in equity or admiralty" are at "protected core" of Article III judicial powers); id. at 458 U. S. 90 (opinion concurring in judgment) (noting that state law contract actions are "the stuff of the traditional actions at common law tried by the courts at Westminster in 1789").
If the identity of the parties alone determined the requirements of Article III, under appellees' theory, the constitutionality of many quasi-adjudicative activities carried on by administrative agencies involving claims between individuals would be thrown into doubt. See 5 K. Davis, Administrative Law § 29:23, p. 443 (2d ed.1984) (concept described as "revolutionary"); Note, A Literal Interpretation of Article III Ignores 150 Years of Article I Court History: Marathon Oil Pipeline Co. v. Northern Pipeline Construction Co., 19 New England L.Rev. 207, 231-232 (1983) ("public rights doctrine exalts form over substance"); Note, The Supreme Court, 1981 Term, 96 Harv.L.Rev. 62, 262, n. 39 (1982). For example, in Switchmen v. National Mediati