Youngstown Sheet & Tube Co. v. Sawyer
Following is the case brief for Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952)
Case Summary of Youngstown Sheet & Tube Co. v. Sawyer:
- Responding to a threatened nationwide steel worker strike and concerned that much-needed steel would not be available to prosecute the Korean War, President Truman ordered federal control over most of the steel mills in the country.
- The owners of the steel mills sued in federal court, seeking an injunction.
- The District Court ordered a preliminary injunction, but the Court of Appeals stayed that decision until the Supreme Court could decide the case.
- The U.S. Supreme Court affirmed the District Court’s injunction, finding that Congress, not the President, has the power to seize private property.
Youngstown Sheet & Tube Co. v. Sawyer Case Brief
Statement of the Facts:
In April 1952, President Truman believed that a threatened nationwide steel worker strike would jeopardize national security because of the need for steel for weapons in the Korean War. Accordingly, the President seized and operated most of the steel mills through an Executive Order. The Order was issued without any statutory authority, but rather purported to be based on the powers vested to the President under the Constitution, and as Commander and Chief of the Armed Forces.
President Truman reported his actions to Congress. Congress did not take any action in response. The executives of the steel companies filed suit in Federal District Court, seeking a declaration that President Truman exceeded his constitutional authority and an injunction halting the President’s operation of the mills.
Procedural History:
- The District Court issued a preliminary injunction.
- The D.C. Circuit Court of Appeals stayed the injunction, pending a decision from the Supreme Court.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Can the President of the United States seize and operate private companies in the absence of congressional authority? No.
Judgment:
The decision of the District Court is affirmed.
Rule of Law or Legal Principle Applied:
The President of the United States, who is charged with executing the laws of the Nation, does not have the legislative authority to seize private property without having the authority granted by Congress.
Reasoning:
The President’s power must stem from either an act of Congress or from the Constitution itself. There is no statute that expressly or impliedly authorizes the President to take possession of property as President Truman did in this case.
There are statutes under which the President could have acted to avoid the impact of the steel worker strike. The President, however, chose not to follow those procedures, finding them too time-consuming and cumbersome given the imminent emergency at hand.
The power to seize private property to help a war effort, however, is a job for lawmakers, not military authorities or those charged with executing the laws. Neither the President’s implied constitutional powers, nor his role as Commander in Chief, gives him any legislative authority. Accordingly, the President’s seizure order cannot stand.
Concurring and Dissenting Opinions:
Concurring Opinion (Frankfurter):
Congress expressly chose, in the Labor Management Relations Act of 1947, not to give the President the power to seize private property as a protective measure to solve a breakdown in industrial relations. Therefore, the President cannot exercise a power that Congress expressly chose not to give.
Concurring Opinion (Douglas):
Both Congress and the President are trustees of the national welfare. Our system of separation of powers was not adopted to promote efficiency but to stop the exercise of arbitrary, unchecked power. Therefore, just because the President can act more quickly than Congress does not mean that the President should have the power he exercised here. The power is legislative in nature, and therefore it is not within the purview of the President. Today the President’s motives may have been good, but tomorrow they may not be.
Concurring Opinion (Jackson):
There are three categories with regard to presidential power. First, the President is at his most powerful when acting under the express authority of Congress. Second, the President’s power is moderate when Congress is silent on an issue. Third, the President is at his weakest when he takes measures incompatible with the expressed or implied will of Congress, for then he can only rely on his constitutional powers. In this case, the President is in the third category, and no constitutional power allows the his order in this case.
Free government requires that the Executive be under the law, and that the law be made by parliamentary deliberations.
Concurring Opinion (Burton):
The division of power is such that Congress has the power to seize private property in emergencies, and the President does not have that power absent instruction from Congress. There were statutory alternatives for the President, which he did not follow. Rather, his order invaded the jurisdiction of Congress.
Concurring Opinion (Clark):
Chief Justice John Marshall in Little v. Barreme halted the President from seizing a vessel coming from France. No Court decision has held differently since then. Where Congress gives the President specific procedures to follow when dealing with a crisis like the steel worker strike, the President must follow those procedures.
Dissenting Opinion (Vinson):
When in extraordinary times, the President has the inherent authority to seize property to further a war effort. The President’s order merely maintained the status quo. Congress can respond by showing its approval or disapproval.
Significance:
Youngstown Sheet & Tube Co. v. Sawyer is a significant case because it was a rebuke to a President who tried to federalize private steel mills outside of congressional authority. It is also a significant opinion because every Justice in the majority wrote a separate opinion, with slightly different reasoning to reach the same result.
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