The Supreme Court heard a challenge by a judge of the Court of Claims to a reduction in his salary. The Court, in accordance with its prior decision in the 1929 ex parte Bakelite case, held that the Court of Claims was a legislative court created under Article I and that its judges therefore lacked Article III protection against diminution of salary. In 1953, Congress declared the Court of Claims to have been established under Article III, thereby giving its judges tenure during good behavior and protection against having their salaries diminished.

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Cases that Shaped the Federal Courts: Glidden Co. v. Zdanok (1962)