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Youngstown Sheet & Tube Co. v. Sawyer

(1952)

Supreme Court of the United States - 343 U.S. 579

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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ICRAIssue, Conclusion, Rule, Analysis for Youngstown Sheet & Tube Co. v. Sawyer

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Facts & HoldingYoungstown Sheet & Tube Co. v. Sawyer case brief 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 | Case Brief DeepDive
Majority opinion, author: Mr. Justice BlackMr. Justice Frankfurter.
Level 1
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This case involves a dispute between steel companies and their employees over new collective bargaining agreements. The President issued Executive Order 10340, directing the Secretary of Commerce to take possession of most of the steel mills to prevent a work stoppage that would jeopardize national defense. The steel companies filed a complaint in the District Court, claiming that the seizure was not authorized by Congress or the Constitution. The Supreme Court ruled that the President's power to seize property to resolve labor disputes and prevent work stoppages was not authorized by Congress. The lower court erred in allowing the seizure to proceed. The President's power to take possession of private property in order to prevent labor disputes from stopping production was not a power granted to the Commander in Chief, but rather a power that should be exercised by Congress. The principle of separation of powers applies to the circumstances of this case, and the seizure order cannot stand. The judgment of the District Court is affirmed.

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Opinion (Concurrence), author: Mr. Justice Frankfurter
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The article emphasizes the importance of checks and balances in a constitutional democracy and the role of the judiciary in interpreting the Constitution and allocating powers appropriately. It discusses a case in which Congress limited and safeguarded the President's power to seize production, transportation, communication, or storage facilities to defined emergencies or limited periods and specified particular circumstances under which it can be exercised. The Labor Management Relations Act of 1947 explicitly denies the President the power of seizure and requires him to report to Congress and ask for specific authority if he thinks seizure is necessary in a particular situation. The Defense Production Act of 1950 and its Amendments do not grant the President seizure power, despite the occurrence of new events such as the Korean conflict. The absence of authority in the President to deal with a crisis does not imply a lack of power in the Government, and the need for new legislation does not enact it or repeal or amend existing law.

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Opinion (Concurrence), author: Mr. Justice Douglas
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The President's seizure of steel plants during an emergency did not grant him constitutional authority to act. Legislative action is necessary to ensure proper consideration and protection of citizens' rights. The decision to seize an industry must be based on a careful analysis of the conditions giving rise to the seizure and the seizure itself. The decision to apply sanctions and involve the courts is a legislative power, and any exercise of legislative power must be done by Congress, not the executive branch. The President's action of taking over an industrial plant to resolve a labor dispute is a legislative act that involves the condemnation of property. The United States must pay compensation for the possession, even if it is temporary. Expanding the President's power in the present emergency would be a violation of Article II of the Constitution. The President's duty to execute the laws starts and ends with the laws enacted by Congress.

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Opinion (Concurrence), author: Mr. Justice Jackson
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The article discusses the idea that executive power has its limitations, and that it is necessary to closely analyze claims of presidential authority in order to maintain a balance within the framework of the Constitution. The Solicitor General's argument that the President's role as Commander in Chief grants him unlimited power, including the power to seize private property, is challenged by the author. It is emphasized that only Congress has the power to declare war and regulate land and naval forces, thus restricting the President's authority over command functions. The Constitution and American history make it clear that military powers were never intended to outweigh representative government of internal affairs. The President can use the army to enforce some civil rights, but is not entitled to execute general laws unless authorized by the Constitution or by Act of Congress.

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Opinion (Concurrence), author: Mr. Justice Burton
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The case deals with the legality of the President's order to seize a steel industry during a national emergency. Congress has the power to authorize actions during such situations and has outlined a specific process for the President to follow. The Taft-Hartley Act provides one such procedure that allows for investigation and collective bargaining but not seizure without the approval of Congress. However, the President did not abide by this procedure and instead referred the matter to the Wage Stabilization Board, which did not result in a resolution. Although Congress reserved the right to consider seizure as a matter of legislative policy, the President's failure to follow the authorized procedure does not cancel out this reservation. The President's executive order to seize the steel properties was issued despite Congress's reserved right to accept or reject that course as a matter of legislative policy.

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Opinion (Concurrence), author: Mr. Justice Clark
Level 1
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The Supreme Court ruled in Little v. Barreme that the President's authority to seize vessels engaged in illicit commerce without special authority is limited by acts of Congress. The President's power during a crisis depends on whether Congress has laid down specific procedures to deal with the crisis. The Defense Production Act of 1950 did not grant the President the power to seize real property except through ordinary condemnation proceedings. The Taft-Hartley Act allows the President to seek injunctive relief for an 80-day period against a threatened work stoppage that imperils national health or safety, but Congress rejected a proposal to allow the President to seize any plant, mine, or facility. The Selective Service Act of 1948 grants the President specific authority to seize plants that fail to produce goods required by the armed forces or the Atomic Energy Commission for national defense purposes. The President exhausted the mediation procedures of the Defense Production Act through the Wage Stabilization Board before seizing the steel mills, but neither the Taft-Hartley Act nor the Selective Service Act authorized the seizure in question.

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Dissenting opinion, author: Mr. Chief Justice Vinson
Level 1
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The legal case discusses the President's broad executive power, including the power to take private property for public use in cases of extreme necessity during times of war or public danger, with full compensation to the owner. The Supreme Court upheld President Truman's seizure of steel mills, stating that the President was performing his duty under the Constitution to "take Care that the Laws be faithfully executed" when he seized the steel mills to prevent a work stoppage in steel production, which would immediately imperil the safety of the Nation by preventing execution of the legislative programs for procurement of military equipment. The Court found that such executive action was consistent with historical practice and did not involve unlimited executive power. Seizure is permissible as long as just compensation is paid. The President's action of seizing the steel mills was to maintain the status quo and prevent the collapse of legislative programs until Congress could act.

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