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Youngstown Sheet & Tube Co. v. Sawyer

    Citation. 343 U.S. 579, 72 S. Ct. 863, 96 L. Ed. 1153, 1952 U.S. 2625.

    Brief Fact Summary. In 1952, after the employees of steel companies threatened to strike, the President of the United States Harry Truman (President Truman) ordered the Secretary of Commerce to seize the Nation’s steel companies. The steel companies sued.

    Synopsis of Rule of Law. The President’s power, if any, to issue an order must stem from an act of Congress or the United States Constitution (Constitution).


    Facts. In 1951, a labor dispute arose between the United States steel companies and their employees. In 1952, the employees union gave notice of a nationwide strike. Thereupon, fearful that such a work stoppage would jeopardize our national defense, President Truman issued an order directing the Secretary of Commerce to take possession of the nation’s steel mills. After obeying the orders under protest, the steel companies brought suit in District Court. The District Court issued a temporary restraining order against the government, which the Court of Appeals stayed.

    Issue. Did President Truman have the authority to order the seizure of the steel mills?

    Held. No. The judgment of the District Court is affirmed.
    Justice Hugo Black stated that there was no statute that expressly conferred upon President Truman the power to seize the mills. There are no provisions of the Constitution, or combination of provisions thereof, which gave the President the authority to take possession of property as he did.

    Dissent. Chief Justice Fred Vinson (J. Vinson) argued that we must consider the context in which the President’s powers were exercised – a national exigency. The President’s power to seize the steel mills derives from his duty to executive legislative programs the success of which depends upon the continued production of steel.
    Concurrence.
    Justice Felix Frankfurter (J. Frankfurter) stated that Congress could not have more emphatically expressed its will that the executive seizure was not authorized than it did in the Taft Hartley Act of 1947.
    Justice Robert Jackson (J. Jackson) said that when the President takes actions inconsistent with the will of Congress, his powers are at their lowest level. Then, he can only rely on his own constitutional powers minus any powers given to Congress on the same matter.
    (Justice Douglas) The branch of government with the power to pay for a seizure is the only one that can authorize one -Congress. If we authorized the President’s act, we would be expanding his powers under Article Two.

    Discussion. This case calls into question the extent and the source(s) of the emergency powers of the President, if any, under the Constitution.


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