White lamented the confused state of the Court's prior jurisprudence in this area, and suggested that instead of attempting to fashion any sort of hard rules about what matters must remain within the cognizance of Article III courts, the court should use a balancing test. Specifically, the Court should examine which Article III values Congress seeks to accommodate or undermine in its legislative scheme, and then weigh this impact against which values Congress hopes to serve by creating Article I courts. In other words, the benefits of a legislative court must be weighed against its effect on separation of powers and judicial independence. White concluded by saying he felt that the Bankruptcy Act of 1978 passed his balancing test.