The constitutionality of agency adjudication turns on a slippery distinction—between public- and private-rights claims—that confounds even the best lawyers. If a right is public, an agency can adjudicate it, subject to judicial review, under the so-called public rights exception. But it may also do nothing and force the government to collect the penalty by filing suit in a federal court. Both carriers argued that the FCC’s adjudication violated their Seventh Amendment right to a federal court jury trial. The Court’s recent decision in AT&T, then, is a win for agency adjudication, but it is only a small win.