Youngstown Sheet & Tube Co. v. Sawyer – Case Brief Summary

Summary of Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 72 S.Ct. 863, 96 L.Ed. 1153 (1952).

The Steel Seizure Case

Facts

The Korean war effort increased the demand for steel. Disputes arose between steel industry management and labor that culminated in an announcement of a strike by the union. President Truman authorized Secretary of Commerce Sawyer to take possession of the steel industry and keep the mills operating.

Issue

  • Does the President of the United States have executive power under the war powers clause of the U.S. Constitution, or any implied powers gleaned therefrom, to authorize the Secretary of Commerce to seize the nation’s steel mills?

Holding and Rule (Black)

  • No. The President does not have implicit or explicit executive power under the war powers clause of the U.S. Constitution, or any implied powers gleaned therefrom, to authorize the Secretary of Commerce to seize the nation’s steel mills.

The court held that there was no explicit statute or act of Congress which authorized the President to act in such a manner. The only two statutes which authorized the acquisition of personal and real property were not met here. Not only were such acts unauthorized, Congress specifically refused to grant such authorization. The court held that in order for the President to have this authority, it must be found somewhere explicitly in the Constitution, or implicitly in some historical context or foundation.

The President cannot order policy; he can only suggest it. Congress can approve any proposal for regulation, policy, settlement of disputes, wages, and working conditions. None of this is delegated to the President. Under a textual approach to interpreting the Constitution the President’s powers are curbed in this extension.

Dissent (Vinson, Reed, and Minton)

Many presidents have taken such action before, most notably Lincoln (Civil War, naval blockade, Emancipation Proclamation), Hayes and Cleveland (authorization of the use of the military to settle strikes) without state or legislative authority.

Concurrence (Frankfurter)

FDR’s actions during the Great Depression resulted in extensions of executive authority, but his authority was not violative of the Constitution. Three laws had already been enacted by Congress when FDR enacted his policy, and six others were only enacted after Congress declared war, thereby falling under the “war powers.”

Concurrence (Jackson)

In determining whether the executive has authority, there are three general circumstances:

  1. When the President acts pursuant to an express or implied authorization of Congress, the President’s authority is at its greatest.
  2. When the President acts in the absence of either a congressional grant or denial of authority, he can only rely upon his own independent powers, but there is a zone in which he and Congress may have concurrent authority. When this is the case, the test depends on the imperatives of events and contemporary imponderables rather than on abstract theories of law.
  3. When the President takes measures incompatible with the expressed or implied will of Congress, the authority of the President is at its lowest.

Justice Jackson stated that this case falls into category three. If the President’s argument were accepted the executive branch could exert its authority over any business or industry.

Notes

The most important part of this case is the three part test set forth in Justice Jackson’s concurrence. This case is also cited as Youngstown v. Sawyer and as Youngstown Sheet Tube v. Sawyer.

See Missouri v. Holland for a case brief of a constitutional law opinion in which the Supreme Court held that Congress has the power under Article II to give effect to a treaty authorized by the President pursuant to the Executive’s treaty power, even if such legislation would otherwise be an unconstitutional interference with states’ rights.


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