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Legal Brief of Youngstown Sheet & Tube Company v. Sawyer (1952) by David A.W. Hittle

Youngstown Sheet & Tube Company v. Sawyer (1952) 343 U.S. 579; 72 S. Ct. 863; 96 L. Ed. 1153 (1952) Vote: 6-3

 

The Facts of the case are these: During the Korean War an imminent strike of the steel workers union would have disrupted the steel needed for the war effort. President Harry S. Truman ordered the Secretary of Commerce to seize the nations steel mills and maintain full production. Youngstown Sheet & Tube Company a “steel producer” filed suit challenging the legality of the President’s order.

 

The Issues in this case are these: 1. Does the President of the United States have the authority to order the take-over of private industries during war time under the Constitution? 2. if not, is this instead a power of the Congress’?

 

By a vote of 6 – 3 the Decision in the case was this: Does the President of the United States have the authority to order the take-over of private industries during war time under the Constitution? No piece of legislation by Congress nor Constitutional article allows for the President to take private property. If not, is this instead a power of the Congress? Yes, Congress can pass legislation either to a. to prevent a strike which would endanger national security, or b. pass legislation allowing the President to do such action.

 

Justice Black opined the majority Opinion: He noted that because the Constitution only allows for the Congress to be the law-making body than the President therefore cannot pass a law, or act in any way that is not a part of his powers or provided to him by Congressional action.

 

Justice Frankfurter, Justice Douglas, and Justice Jackson concurred with Justice Black in giving a separate Concurring Opinion: He provides the following points for the President and other challengers of the opinion of the Court: 1. “When the President acts pursuant to an expressed or implied authorization of Congress, his authority is at its maximum, for it includes all that he possess in his own right plus all that Congress can delegate. In these circumstances and in these only may he be said (for what it is worth) to personify the federal sovereignty…. 2. When the President acts in absence of either a congressional grant or denial of authority, he can only rely upon his own independent power, but there is a zone of twilight in which he and Congress may have concurrent authority, or in which its distribution is uncertain…. In this area, any actual test of power is likely to depend on the imperatives of events and contemporary imponderable rather than on abstract theories of law. 3. 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 rely only upon his own Constitutional Powers minus any constitutional powers of Congress over the matter…. Justice Burton and Justice Clark concurred with the above concurrence.

 

Chief Justice Vinson, Justice Reed and Justice Minton Dissent and in their opinion: The opinion that the President had many different authorities in the area of this case and that he was following the Constitution when he “[took] care that the laws be faithfully executed.” As required by the Constitution of the United States.

 

The Significance of this case is that it limited the President’s power to those provided to him by the Congress and/or those which are expressly his own.