Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952)

Material Facts:

Harry Truman in an attempt to avert a nation-wide strike of steel workers ordered the Secretary of Commerce to seize and operate the country’s steel mills. The order by the president did not stem from any specific statutory authority, but was deemed an exercise of presidential power following from the believe that a halt in steel protection will jeopardize national security. In line with the order, steel mills were seized and expected to operate in accordance with the directives of the secretary of commerce. The steel companies sought a declaration from the court that the president had no constitutional power to issue the order.

Procedural History:

The steel companies brought an action against the secretary at the District Court for an injunction against the seizure, and the injunction was issued. On appeal, the court of appeal stayed the injunction. The case was referred to the supreme court for determination.

Issues:

1. Whether or not the seizure order was within the constitutional power of the president.

Arguments of the Defendant:

1. That the seizure was an exercise of the president’s military power as commander in chief of the armed forces.

Holding:

1. The seizure of the property was not within the constitutional power of the president.

Ratio Decidendi:

Justice Black in delivering the opinion of the court stated that the power to issue the seizure order must stem from an act of congress or from the constitution itself. No statute or constitutional provision was found to have conferred such power on the president and that congress had in the past refused to adopt seizure as a dispute setting mechanism. The power to seize private property was thought to be the exclusive power of congress and not the executive.