The case of Atlas Roofing Co., Inc. v. Occupational Safety and Health Review Commission et al., 1976, revolved around the issue of whether or not administrative law judges could impose penalties on businesses without a jury trial, which Atlas Roofing argued was in violation of their Seventh Amendment rights to a jury trial. The U.S Supreme Court ruled against Atlas Roofing, stating that the Seventh Amendment did not apply to cases involving public rights and statutory causes - such as those created by Congress when it established the Occupational Safety and Health Act (OSHA). Therefore, OSHA's use of non-Article III tribunals to enforce its standards was constitutional because these proceedings involve public rights between government and persons subject to its authority in connection with performance of federal functions under regulatory schemes.

In the dissenting opinion for Atlas Roofing Co., Inc. v. Occupational Safety and Health Review Commission et al., Justice Powell argued that the majority's decision to uphold administrative fines without a jury trial was inconsistent with the Seventh Amendment, which guarantees a right to a jury trial in civil cases where penalties are sought by government agencies. He contended that this case involved "public rights" rather than "private rights," as it dealt with regulatory measures designed to protect public safety, not just resolve private disputes between parties. Therefore, he believed it should have been subject to judicial review and entitled to a jury trial under constitutional law principles. Furthermore, he expressed concern about potential abuses of power if such matters were left solely within an agency’s discretion without proper checks from judiciary bodies.