White also felt that the plurality incorrectly defined the "Crowell" and "Raddatz" cases as the outer limits of Congressional authority to create non-Article III tribunals, and ignored both prior bankruptcy and administrative law practice. He noted that not only did bankruptcy judges have many of the same powers as the “referees” under the old law, but that District Courts were given greater latitude in judicial review of bankruptcy court decisions than they had when sitting in review of administrative agency actions (see also: Administrative Procedure Act).