Youngstown Sheet & Tube Co. v. Sawyer (1952)

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Youngstown Sheet & Tube v. Sawyer, 342 U.S. 579 (1952) was a case in which the U.S. Supreme Court had to decide on the applicability of the President's national security powers on seizing private property. President Truman had ordered the Secretary of Commerce to take possession of and operate the mills in order to maintain steel production during the Korean War. The Supreme Court held that President Truman lacked either constitutional or statutory authority to seize the nation's strike-bound steel mills (the Court noted, however, that Congress would have had constitutional authority to do so). 


The setting of Youngstown took place during the period of the Korean War. In 1951, a labor dispute had arisen between steel companies and their employees. As a result of the parties' failure to reach a collective bargaining agreement, the workers went on strike which paused the production of then much-needed steel for war materials. 

Fearing that such a stoppage would pose a threat to national security, President Harry S. Truman issued an executive order directing the Secretary of Commerce, Charles Sawyer, to seize the steel mills to keep them running. The steel companies brought action alleging that the seizure was unconstitutional. 

Procedural History

The District Court held against Sawyer and issued a preliminary injunction preventing the Secretary from continuing the seizure and possession of the plants. Following the Court of Appeals stay on the District Court's injunction, the Supreme Court granted certiorari to decide the issue. 


Ultimately, the Supreme Court, in a 6-3 decision held that President Truman's actions were unconstitutional as they were not explicitly authorized by an act of Congress, nor could the action be reasonably construed as carrying out one of the authorities granted to the President. As to the government's argument that the order was authorized under the President's power as Commander and Chief, the Court responded that such powers did not include authorizing the President to seize private property to prevent labor disputes from interrupting production. 

Justice Jackson's Concurrence

Justice Jackson's concurrence in this case also provided a tripartite scheme that courts would later apply to determine the constitutionality of presidential power (e.g., Zivotofsky ex rel. Zivotofsky v. Kerry, 576 U.S. 1 (2015); Medellin v. Texas, 552 U.S. 491 (2008)). Namely, Justice Jackson explained that the President's power is greatest when the sought action is expressly authorized by Congress. Second, when Congress is silent on whether a certain presidential action is authorized, the President must rely on his power as the executive. Here, the constitutionality of the actions may rest of circumstances. Lastly, when the President takes action that goes against congressional authority, his power "is at its lowest ebb." 

[Last updated in April of 2022 by the Wex Definitions Team]