Youngstown Sheet & Tube Co. v. Sawyer

343 U.S. 579 · Supreme Court of the United States · 1952

Constitutional Law Assigned in 29 casebooks

Case brief summary

Rule

The President cannot make new law or take private property to settle a labor dispute unless Congress has given him that power, because only Congress can pass laws under the Constitution.

Facts

Steelworkers planned a nationwide strike, so the President ordered the government to seize and run most steel mills to keep producing steel for the Korean War effort, without citing any specific law giving him this authority.

Procedural history

The steel companies sued in federal district court, which blocked the seizure with a preliminary injunction, then the appeals court paused that block, and the Supreme Court agreed to hear the case quickly.

Issue

Did the President have constitutional or legal authority to order the government to take over and run the steel mills without a specific law from Congress allowing it?

Holding

The President's seizure order was not authorized by the Constitution or by any law, so it could not stand and the mills had to be returned.

Reasoning

Congress never gave the President this power, and even rejected it once before. His role as military commander does not let him take over private businesses just to settle a labor dispute.

Opinions

Majority (Black): The seizure was an attempt by the President to make law, which belongs only to Congress, and no statute or constitutional power authorized it.

Concurrences (Frankfurter, Douglas, Jackson, Burton, Clark): Each justice agreed the seizure was illegal mainly because Congress had already set up specific procedures for such emergencies and the President ignored them.

Dissent (Vinson, joined by Reed and Minton): The President acted lawfully and necessarily to keep steel flowing for national defense until Congress could act, following a long history of presidents taking emergency action.

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What prompted President Truman to issue Executive Order 10340?

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