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Youngstown Sheet & Tube v. Sawyer

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Youngstown Sheet & Tube Co. v. Sawyer 343 U.S. 579

Facts: In 1951, the United Steelworkers Union decided to call a strike after a protracted battle with the industry. This was a most inopportune time for a labor dispute as the country was in the midst of the Korean War. Federal mediators tried to bring matters to a conclusion, but to no avail. President Truman, none too pleased with the news, ordered the Secretary of Commerce to seize American steel mills in the name of the United States to keep them running. Mill owners cooperated but lodged their protest in Federal District Court, arguing that not only was there no statue concerning Truman’s authority, but also that the Taft-Hartley Act specifically prohibited a takeover of industry to resolve a labor dispute, suggesting instead an 80-day cooling off period. The District Court ruled in favor of the steel companies, but an Appeals court stayed the injunction, paving the way for the Supreme Court to intervene.

Question: Do circumstances and the inherent powers of the executive absent any Constitutional or statutorily granted authority allow the President to seize and operate privately owned steel mills?

Holding: No. The Court ruled 6-3 to affirm the District Court ruling. The Constitution does not endow the president with the authority to take the action in question.

Rationale: Justice Black, writing for the majority, breaks down the case into statutory and Constitutional issues. Simply put, Presidential authority is granted either by Congress or the Constitution itself. The respondent argued that the President’s Constitutional Article II powers grant him executive power, the power to “take care that the Laws are faithfully executed,” and the power of being Commander in Chief. Black refutes each of these constitutional claims. He states that all precedent regarding liberties granted the executive in his function as Commander in Chief related specifically to actions taken in the theater of war. Because the resolution of a labor dispute on American soil, even if it occurs during wartime, does not qualify as such a case, that provision does not hold water. Black argues that the very nature of the Take Care clause actually hurts the president’s case, as it refers to the idea that he should take care to execute laws that are put in place by Congress. It “refutes the idea that he is to be a lawmaker.” In establishing the president’s action as a legislative one, he also bars its consideration under any presidential executive power, as lawmaking is fundamentally outside of that province. Black also confronts the Congressional side of the coin, stating that Congress dictates what the policies shall be, and the president ought to execute them. The president cannot and must not do both. He argues that, if Congress wanted to pass a law authorizing the president to seize the mills, then by all means should it do so. However, absent any Constitutional basis, the president may not unilaterally take this action.

Justice Jackson concurred, arguing that the context of Constitutional provisions within the document matters, and that document dictated a fluctuating balance between the branches. Under this logic, if the president acts against the wishes of Congress, then it must be in direct pursuance and clearly under the province of his independent powers. Because the President acted against the wishes of Congress, his actions must be held to the highest standard. 

Chief Justice Vinson dissented, arguing that the context of war trumped the considerations above.