Brennan held that the dispute in question here was an adjudication of private rights, because it involved the restructuring of creditor-debtor relations under the bankruptcy laws. Thus, none of the three exceptions to Article III jurisdiction were applicable. He further held that Congress’ power under the Naturalization and Bankruptcy Clause (Art. I, § 8, cl.4) of the Constitution did not carry with it a power to create specialized tribunals for the adjudication of bankruptcy cases. Brennan feared that reading such a power into Article I would erode the jurisdiction conferred by Article III and displace the judicial branch of the government.