Youngstown Sheet & Tube Co. v. Sawyer

In 1947, over the veto of Harry Truman, Congress passed the Taft-Hartley Act to make labor unions weaker. Nonetheless, the Taft-Hartley Act had expressly prohibited seizures of companies (nationalization) to resolve labor disputes with unions.

There was a labor strike in the steel industry, and President Truman ordered his Secretary of Commerce Sawyer to take possession of the steel mills.

His Secretary ordered the steel company owners to keep their mills open, which meant they probably had to give in to the steel union’s demands. Truman argued that he had this power because of his power as commander in chief, and the steel industry directly affect the power to defend the country.

Youngstown (representing steel mills) wins in the United States District Court for the District of Columbia against Sawyer.

Whether the President has the power to take possession of private property in order to keep labor disputes from stopping production due to his position of Commander in Chief.

Justices Jackson, Burton, Douglas, and Clark argued that Truman has acted unconstitutionally because Congress had expressly declined to authorize the seizure of the steel mills.

President Truman believed that during the emergency of the Korean War in the 1950s, he acted to circumvent the halting of the steel production which was needed for the war.

Because Congress had considered this issue and laws existed that allowed for other methods of resolving these issues, the President misused his power.

Perhaps if the Congress was silent on the issue it would invite Presidential action since the emergency would require immediate, decisive action.

Congress had not formally declared war during the Korean War in the early 1950s.

Emergencies do not create power, but merely mark occasions when power should be executed.

The Congress is entrusted with lawmaking powers, and the branch of government that has the power to pay compensation for a seizure is the only one able to authorize a seizure or make lawful one that the President has effected.

Dissent:

We are involved in Korea, and a work stoppage would immediately jeopardize and imperil our national defense. The President immediately informed Congress of his action and clearly stated his intention to abide by the legislative will.

This case is also known as the Steel Seizure Case.