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Youngstown Sheet & Tube Co. v. Sawyer

343 U.S. 579 (1952)

tl;dr: President needs authorization from Congress or the Constitution to issue an executive order. Establishes tripartite framework for analysis of President's power in Jackson's concurrence.

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Youngstown Sheet & Tube Co. v. Sawyer addressed the limits of the President's authority to seize private property in cases of labor disputes. The Supreme Court ruled that the President cannot seize property without explicit authorization from Congress or the Constitution. This decision upheld the principle of separation of powers by limiting the President's power. In the event of a national defense emergency, the President may instruct the United States to take control of steel company plants, but only if authorized by the Secretary of Commerce and with recognition of workers' rights. The court must use caution when addressing executive seizure of production, transportation, communications, or storage facilities, as it is an extraordinary authority that must be carefully limited. The government's actions are restricted by the law, and claims of inherent and unlimited presidential powers lack clear meaning. The court cannot modify the Constitution to include undefined emergency powers for the Executive, and the President cannot assign himself undefined emergency powers.

The Weimar Constitution's provision allowing the President to suspend individual rights without parliamentary approval led to Hitler's abuse of power. Emergency powers should be subject to legal restraint and not solely in the Executive. The President cannot seize private property without Congress's authorization, and the lower court erred in allowing the seizure to stand. The President's authority in times of national emergency may be necessary, but unconstitutional measures are not lawful. The President has the power to use eminent domain in an emergency without waiting for Congress, but private property owners must be compensated. The President's authority is limited to performing specific executive acts authorized by an implied law based on the situation. The Neagle case doctrine states that the Executive has the authority to use the power of the United States to protect government agencies, instrumentalities, or property. President Truman's decision to seize the steel mills was necessary to protect national safety and execute legislative programs. The Defense Production Act of 1950 acknowledges the need for effective procedures to resolve labor disputes affecting national defense. The President's action was effective in saving legislative programs until Congress could act, and was in accordance with the Constitution. The District Court's order should be reversed.

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Facts & Holding

Facts:During the Korean War, a labor dispute developed between steel...

Holding:The President's power to issue executive orders must come from...

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Youngstown Sheet & Tube Co. v. Sawyer

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