Youngstown Sheet & Tube Co v. Sawyer

Key Facts– The President, concerned that a steel workers’ strike would create a national steel shortage, which he considered likely to be a national security crisis, ordered the seizure of all American steel mills to ensure the continued availability of steel. The Secretary of Commerce complied with the President’s orders and issued his own commands to effect the seizure.

Procedural History– The steel companies began proceedings in District Court, and they obtained an injunction barring the government from holding the mills. The government appealed, and the Court of Appeals stayed the injunction, conditional on the government filing for certiorari. After both the government and steel companies filed for certiorari, the Supreme Court agreed to hear the case.

Issues– Was the President acting within his constitutional power when he ordered the Secretary of Commerce to seize and operate most of the nation’s steel mills?

Holding– No, he was not.

Results– Steel mills returned to their owners, and the strike commenced.

Reasoning– There is nothing in the Constitution to suggest the President has authority to seize property and take over businesses, and the impending labor conflict does not change that. Unless Congress grants such authority, there have been no occasions when the President has been able to use it. Since his authority to do this outside of wartime and without Congressional authorization is nonexistent, he was certainly not able to do this.

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