Youngstown Sheet & Tube Co. v. Sawyer

Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952), is a landmark decision of the United States Supreme Court.

During the Korean War, President Truman issued an executive order directing the Secretary of Commerce to seize and operate the nation’s steel mills to avert a strike that would disrupt war production. The steel companies sued, arguing that the President had no constitutional authority to seize private property without congressional authorization.

Significance

Justice Black’s 6-3 opinion struck down the seizure as an unconstitutional exercise of presidential power. The President’s power must come from either an act of Congress or the Constitution itself. Congress had specifically rejected giving the President seizure authority in the Taft-Hartley Act, and the Constitution’s Commander-in-Chief Clause does not authorize domestic economic seizures. Justice Jackson’s famous concurrence articulated a three-part framework for evaluating presidential action based on the degree of congressional authorization, which has become a cornerstone of separation-of-powers analysis.

Category

US Federal Case Law