Youngstown Sheet & Tube Co. v. Sawyer
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 silence did 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 by any 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 and beyond control by Congress . . . I am not persuaded, that history leaves open to question . . . that the executive branch, like the Federal Government as a whole, possesses only delegated powers. The purpose of the Constitution was not 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 when the industry agreed to wage increases. The long term effect of the Steel Seizure 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 control over 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 fact that 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 about the 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.
Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1941 to 1953Youngstown Sheet Tube Co. v. Sawyer - Significance, Supreme Court Rebuffs Presidential Claims Of Inherent Authority, Further Readings