Youngstown Sheet & Tube Co v.

Sawyer (1952)

Also known as Steel Seizure Case

Plaintiff: Youngstown Sheet & Tube Company

v.

Respondent: Charles Sawyer, Secretary of Commerce

OPINION 6-3 for Youngstown Sheet & Tube Co

 BACKGROUND

The Korean War is often characterized as a proxy war during the broader Cold War between the United
States and its allies, and the Soviet Union and China.

As tensions between the two superpowers escalated, Korea became a geopolitical battleground where
each side sought to expand its influence.

The U.S. involvement in supporting South Korea was driven by its policy of containment, aiming to
prevent the spread of communism.

FACTS

During the Korean War, the government heavily relied on the steel industry as it played a crucial role in
supplying materials for the war.

Using this reliance as an advantage, The United Steel Workers of America planned a nationwide strike
due to the industry's refusal to increase wages.

The strike involved major steel producing companies.

With the strike coming up and both sides unwilling to compromise, Truman decided to seize steel
production facilities of companies.

Truman wanted to ensure a continuous supply of materials of war for the troops in Korea.

But Truman had alternative ways for seizing the production facilities, such as using the Taft-Hartley Act
to declare a national emergency or the Selective Service Act.

However, Truman deemed them impractical for the urgent situation.

What Truman ultimately did was relied on his inherent powers as President during an emergency.

Without gaining special Congressional authorization he issued an Executive Order directing the
Secretary of Commerce, Charles Sawyer to seize and operate most of the steel mills.

Thus, the steel producing companies opposed the seizure and sought an injunction claiming the seizure
has unconstitutional grounds since president took the action without congressional authority.
 FEDERAL DISTRICT COURT

The steel companies sued the Secretary in a Federal District Court, praying for a declaratory judgment
and injunctive relief.

The steel companies questioned President Truman’s action’s constitutional basis. As a response to it, the
attorney for the government asserted that president of US possesses broad presidential powers and did
not even have a legal precedent to rely on. This backfired.

Thus, the District Court issued a preliminary injunction.

CIRCUIT COURT (APPELLATE)

The Government then appealed against the injunction to the circuit court. And the Circuit Court granted
a stay order on the injunction. Thus the steel companies then approached Supreme Court.

ISSUE BEFORE SC

Whether the President was acting within his constitutional power when he issued an order directing the
Secretary of Commerce to take possession of and operate most of the Nation's steel mills.

SUPREME COURT

The SC in this case ruled that The President's power to issue the order must stem either from an act of
Congress or from the Constitution itself.

There is no statute that expressly authorizes the President to take possession of property as he did here.
Nor is there any act of Congress to which our attention has been directed from which such a power can
fairly be implied.

The acts which authorize the President to take private property (Taft-Harley Act & Selective Service Act)
have their own conditions and procedures which the government has agreed itself were not followed.

Moreover, these acts authorizing such seizure were not passed by the approval of congress but by the
president’s veto power, thus such actions of seizure have always been opposed by the congress.

The Court also ruled out the possibility of such power vesting in the President because of him being the
Commander in Chief of the US Army as the constitution does not support such idea either.

The Court even asserted that the seizure order goes beyond the scope of executing laws passed by
Congress and, instead, involves the President in a lawmaking role.

The judge emphasizes that the Constitution grants the President the authority to execute laws faithfully
but not to create new laws independently.

Thus, the president in doing so is acting out of his authority, without congressional approval or
constitutional authority.
For this reason the court ruled in favor of Steel Companies and the seized steel producing facilities were
rightfully asked to be returned to their companies.

The Justices highlighted that even during time of emergencies, the President’s powers does not increase
nor decreases, it stays the same.

Another helping element was how Justice Jackson delivered the “familiar tripartite scheme” that the
Supreme Court has since called “the accepted framework for evaluating executive action”

(in descending order of legitimacy):

Cases in which the President was acting with express or implied authority from Congress:

“When the President acts pursuant to an express or implied authorization of Congress, his
authority is at its maximum, for it includes all that he possesses in his own right plus all that
Congress can delegate.”

Cases in which Congress had thus far been silent, referred to as a "zone of twilight":

“When the President acts in absence of either a congressional grant or denial of authority,
he can only rely upon his own independent powers, but there is a zone of twilight in which he
and Congress may have concurrent authority, or in which its distribution is uncertain.”

In such a circumstance, Presidential authority can derive support from “congressional

inertia, indifference or quiescence

Cases in which the President was defying congressional orders (the "third category"):

“When the President takes measures incompatible with the expressed or implied will of
Congress, his power is at its lowest ebb,”

the Court can sustain his actions “only by disabling the Congress from acting upon the
subject.”

The current actions of President fell in the third category proving that such actions were illegitimate and
will not be supported.
 SIGNIFICANCE

Judicial Review: The case reflects the exercise of judicial review by the courts to assess the
constitutionality of executive actions. The judge affirms the District Court's decision, indicating the
judiciary's role in upholding constitutional principles and checking potential overreach by the executive
branch, thereby reinforcing the familiar tripartite scheme of governance.

Familiar Tripartite Scheme: Justice Jackson's tripartite framework is significant because it provides a
method for evaluating the constitutionality of executive actions, particularly in situations involving the
separation of powers between the President and Congress. It served as an influential tool for future
cases viewed by the Supreme Court of similar nature.

Executive Authority (Presidential Power): The case raises questions about the extent of the President's
executive authority, particularly in times of national emergency eliminating the idea that the President,
through inherent powers, can unilaterally seize private property without explicit congressional approval,
highlighting the need for checks on executive power.

Congressional Authority (Legislative Power): The judgment emphasizes the exclusive authority of
Congress to make laws, as outlined in the Constitution's first article. It contends that the President's
order, prescribing a policy without proper legislative authorization, intruded upon the lawmaking
powers vested solely in Congress.

Constitutional Limits: The judge underscores that even in challenging times, constitutional limits on
executive power must be upheld. The Founders' intent to entrust lawmaking power solely to Congress is
reiterated, emphasizing the enduring significance of constitutional principles in both favorable and
adverse circumstances.