Brennan then turned to Northern's argument that the bankruptcy courts were merely adjuncts to the U.S. District Courts. He framed the Constitutional issue as the determination whether the Bankruptcy Act retained “the essential attributes of judicial power” inherent in Article III tribunals. He began his analysis by examining two prior cases: "Crowell v. Benson", 285 U.S. 22 (1932), in which the court permitted the United States Employees' Compensation Commission to make factual determinations in the issuance of compensation orders for individual employees; and "United States v. Raddatz", 447 U.S. 667 (1980), in which the court upheld the Federal Magistrates Act, which permitted district court judges to refer certain pretrial motions to magistrates for initial determination. These cases provided limits on the extent to which Congress may transfer traditionally judicial functions to non-Article III tribunals. For example, Congress has substantial discretion in prescribing the manner in which rights created by its own statutes may be enforced, but Congress has no such discretion in altering the adjudication of rights it has not created by statute. Furthermore, the functions of the adjunct court must be limited in such a way so as to preserve the parties’ rights to adjudication before an Article III court.