Youngstown Sheet & Tube Co. v. Sawyer

Also known as the Steel Seizure Case, Youngstown is of lasting importance 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 Korean peninsula 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 of the 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 branch seizure 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--and that 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, the outcome of which was vital not just to the war effort but to the U.S. economy.