Petitioner
Youngstown Sheet & Tube Co.
Respondent
Charles Sawyer, Secretary of Commerce
Petitioner's Claim
That in seizing control of steel production during the Korean War in order toprevent a labor strike, the executive branch exceeded its constitutional authority.
Chief Lawyer for Petitioner
John W. Davis
Chief Lawyer for Respondent
Philip B. Perlman, Solicitor General
Justices for the Court
Hugo Lafayette Black (writing for the Court), Tom C. Clark, William O. Douglas, Robert H. Jackson, Sherman Minton, Stanley Forman Reed, Fred Moore Vinson
Justices Dissenting
Harold Burton, Felix Frankfurter
Place
Washington, D.C.
Date of Decision
2 June 1952
Decision
The Supreme Court ruled against the executive branch steel seizure.
Significance
Also known as the Steel Seizure Case, Youngstown is of lastingimportance because it upheld the balance of power between the executive and legislative branches.
In 1952, United States troops were still engaged in hostilities on the Koreanpeninsula while the United Nations attempted to negotiate an armistice. On 20 March of that year, after the steel industry refused to abide by a Wage Mediation Board award, steel workers threatened to go out on strike. Because ofthe threat to production in an industry so vital to U.S. military action, President Harry S. Truman issued an executive order commanding Secretary of Commerce Charles Sawyer to seize control of the nation's steel mills. Sawyer directed the steel companies to operate according to government regulations.
The president immediately gave Congress formal notice of his action, and Congress took no action in response. Truman based his actions on the executive power vested in him by Article II of the Constitution and by his powers as commander-in-chief, as well as the many historical precedents of executive branchseizure of industry without congressional approval. Steel industry executives, however, argued that the controlling law was the Taft-Hartley Labor-Management Relations Act of 1947, which permitted Congress to become involved--andthat it could be employed only after collective bargaining broke down. The history of the act showed that during debate over Taft-Hartley, Congress had specifically rejected a provision authorizing executive branch seizure of industries experiencing labor strife.
On 30 April 1952, the U.S. District Court for the District of Columbia granted Youngstown Sheet & Tube and other steel industry plaintiffs a preliminary injunction barring the executive branch from controlling the steel mills.This injunction was stayed the same day by the District of Columbia Circuit Court of Appeals. On 3 May, the Supreme Court agreed to review this case, theoutcome of which was vital not just to the war effort but to the U.S. economy.
Supreme Court Rebuffs Presidential Claims of Inherent Authority
On 2 June 1952, the Court handed down its opinion. Writing for the Court, Justice Black declared that the president had no power to intervene in labor disputes without express consent of the Congress. To do so was to exercise a legislative function and therefore violate the doctrine of separation of powers.Four of the five justices who joined his opinion-- Jackson, Clark, Douglas,and Frankfurter--also wrote concurring opinions of their own. Of these, Jackson's was the most salient regarding the most contentious issue in the case: Congress's silence in the face of Truman's actions. For Jackson, this silencedid not indicate acquiescence but a refusal to authorize the seizure:
There was, in short, no inherent executive power to seize private industry. After the Court ruled the steel seizure unconstitutional, the United Steel Workers called for another strike, but this was promptly settled on 24 June whenthe industry agreed to wage increases. The long term effect of the SteelSeizure Case decision was to restrain presidential claims of implied authority in such areas as executive privilege and national security. In practice, however, the Court itself has shown great deference to the president's claims of implied powers. It has upheld inherent presidential authority in the area of foreign affairs, which has traditionally separated legislative controlover domestic affairs from executive authority over external matters. In Dames & Moore v. Regan (1981), for example, the Court condoned President Jimmy Carter's resolution of the hostage crisis with Iran despite the factthat his actions went beyond the powers granted him by law. In other areas,the Court has declined to recognize implied executive powers. But even in United States v. Nixon (1974), in which the Court rejected President Richard Nixon's attempts to hang on to his tape recordings of conversations aboutthe Watergate break-in and cover up, the Court stressed that the executive branch is entitled to great deference in protecting the confidentiality of presidential affairs, both foreign and domestic.
Related Cases
Youngstown Sheet & Tube Co.
Respondent
Charles Sawyer, Secretary of Commerce
Petitioner's Claim
That in seizing control of steel production during the Korean War in order toprevent a labor strike, the executive branch exceeded its constitutional authority.
Chief Lawyer for Petitioner
John W. Davis
Chief Lawyer for Respondent
Philip B. Perlman, Solicitor General
Justices for the Court
Hugo Lafayette Black (writing for the Court), Tom C. Clark, William O. Douglas, Robert H. Jackson, Sherman Minton, Stanley Forman Reed, Fred Moore Vinson
Justices Dissenting
Harold Burton, Felix Frankfurter
Place
Washington, D.C.
Date of Decision
2 June 1952
Decision
The Supreme Court ruled against the executive branch steel seizure.
Significance
Also known as the Steel Seizure Case, Youngstown is of lastingimportance because it upheld the balance of power between the executive and legislative branches.
In 1952, United States troops were still engaged in hostilities on the Koreanpeninsula while the United Nations attempted to negotiate an armistice. On 20 March of that year, after the steel industry refused to abide by a Wage Mediation Board award, steel workers threatened to go out on strike. Because ofthe threat to production in an industry so vital to U.S. military action, President Harry S. Truman issued an executive order commanding Secretary of Commerce Charles Sawyer to seize control of the nation's steel mills. Sawyer directed the steel companies to operate according to government regulations.
The president immediately gave Congress formal notice of his action, and Congress took no action in response. Truman based his actions on the executive power vested in him by Article II of the Constitution and by his powers as commander-in-chief, as well as the many historical precedents of executive branchseizure of industry without congressional approval. Steel industry executives, however, argued that the controlling law was the Taft-Hartley Labor-Management Relations Act of 1947, which permitted Congress to become involved--andthat it could be employed only after collective bargaining broke down. The history of the act showed that during debate over Taft-Hartley, Congress had specifically rejected a provision authorizing executive branch seizure of industries experiencing labor strife.
On 30 April 1952, the U.S. District Court for the District of Columbia granted Youngstown Sheet & Tube and other steel industry plaintiffs a preliminary injunction barring the executive branch from controlling the steel mills.This injunction was stayed the same day by the District of Columbia Circuit Court of Appeals. On 3 May, the Supreme Court agreed to review this case, theoutcome of which was vital not just to the war effort but to the U.S. economy.
Supreme Court Rebuffs Presidential Claims of Inherent Authority
On 2 June 1952, the Court handed down its opinion. Writing for the Court, Justice Black declared that the president had no power to intervene in labor disputes without express consent of the Congress. To do so was to exercise a legislative function and therefore violate the doctrine of separation of powers.Four of the five justices who joined his opinion-- Jackson, Clark, Douglas,and Frankfurter--also wrote concurring opinions of their own. Of these, Jackson's was the most salient regarding the most contentious issue in the case: Congress's silence in the face of Truman's actions. For Jackson, this silencedid not indicate acquiescence but a refusal to authorize the seizure:
When the President takes measures incompatible with the expressed or implied will of Congress, his power is at its lowest ebb, for then he can only rely upon his own constitutional powers minus any constitutional powers of Congress over the matter . . . the current seizure . . . can be supported only byany remainder of executive power after subtraction of such powers as Congress may have over the subject. In short, we can sustain the President only by holding that seizure of such strike-bound industries is within his domain andbeyond control by Congress . . . I am not persuaded, that history leaves opento question . . . that the executive branch, like the Federal Government asa whole, possesses only delegated powers. The purpose of the Constitution wasnot only to grant power, but to keep it from getting out of hand.
There was, in short, no inherent executive power to seize private industry. After the Court ruled the steel seizure unconstitutional, the United Steel Workers called for another strike, but this was promptly settled on 24 June whenthe industry agreed to wage increases. The long term effect of the SteelSeizure Case decision was to restrain presidential claims of implied authority in such areas as executive privilege and national security. In practice, however, the Court itself has shown great deference to the president's claims of implied powers. It has upheld inherent presidential authority in the area of foreign affairs, which has traditionally separated legislative controlover domestic affairs from executive authority over external matters. In Dames & Moore v. Regan (1981), for example, the Court condoned President Jimmy Carter's resolution of the hostage crisis with Iran despite the factthat his actions went beyond the powers granted him by law. In other areas,the Court has declined to recognize implied executive powers. But even in United States v. Nixon (1974), in which the Court rejected President Richard Nixon's attempts to hang on to his tape recordings of conversations aboutthe Watergate break-in and cover up, the Court stressed that the executive branch is entitled to great deference in protecting the confidentiality of presidential affairs, both foreign and domestic.
Related Cases
- Dalton v. Specter, 511 U.S. 462 (1994).
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