Several federal agencies, including the Securities and Exchange Commission and the Federal Trade Commission, have statutory power to use an internal administrative court system to decide whether a person committed an alleged violation of law and, if so, to order various remedies such as monetary penalties, other types of payment, and limitations on the defendant’s activities. These agency adjudications of enforcement charges, call them administrative proceedings or APs, have been strongly criticized for depriving defendants of constitutional protections. For example, in