Youngstown Sheet & Tube Co. v. Sawyer | 1952
University of North Carolina Law School Professor
University of Chicago Politics Professor
Choose a video from the playlist below
  • Youngstown Sheet & Tube Co. v. Sawyer full program
  • Justice Kagan on Youngstown
  • Presidents and the Constitution
  • Justice Sotomayor on Youngstown
  • Justice Ginsburg on Youngstown and Judicial Authority
  • Sen. Edward Kennedy on Youngstown and Executive Power
  • Justice Jackson's Concurrence
  • Youngstown's Steel Industry
  • United Steel Workers of America Strike
  • Frank Purnell & Youngstown Sheet & Tube Co.
  • Wage Stabilization Board
Subject: Limiting presidents’ power to seize private property
Case Decided:
June 2, 1952

Youngstown Sheet and Tube Company v. Sawyer (1952) significantly curbed executive power when the Court overturned President Truman’s seizure of steel mills during the Korean War. The Court ruled 6-3 that the President’s actions were unconstitutional because they had not been authorized by Congress. By deciding that the Constitution gives Congress and not the president this authority, the Court affirmed the “separation of powers” essential to American government.

In 1952, nearly two years into U.S. involvement into the Korean War, the United Steel Workers of America clashed with industry managers and threatened to strike for higher wages. Steel was an integral part of the war effort, and President Truman felt he couldn’t risk a halt in production. Rather than using labor laws passed by Congress to avert a strike, he ordered his secretary of commerce, Charles Sawyer, to seize and operate the steel mills. Appeased, the union called off the strike, but the steel companies immediately fought back against the President’s seizure of their property. The Court sided with the companies, concluding that nothing in the Constitution authorized the president to seize property in wartime without approval from Congress. While cases like Schenck and Korematsu point to the expanded powers of the executive branch during wartime, Youngstown serves as a reminder that these powers have their limits.

Key Players
President Harry Truman

Harry Truman (May 8, 1884 – December 26, 1972) was president of the United States (1945 – 1953) during the Korean War. He exercised executive power frequently, seizing 28 industrial properties in labor disputes during the first year and a half of his presidency. His decision to involve the U.S. in the Korean War without consulting Congress led some Americans to call it “Harry’s War.”

Chief Justice Fred Vinson

Fred Vinson (January 22, 1890 – September 8, 1953) was appointed by President Truman as chief justice of the Supreme Court (1946 – 1953). Historians have reported that before Truman seized the steel mills, Vinson privately assured him that it was constitutional to do so. In his dissent in Youngstown, Vinson defended the President’s actions and argued that he should have increased authority in times of war.

Justice Robert Jackson

Robert Jackson (February 13, 1892 – October 9, 1954) was a Supreme Court justice (1941 – 1954) who wrote a concurring opinion in Youngstown. In it, he suggested three tiers of presidential power: with authority from Congress, when Congress is silent, and in defiance of Congress. He concluded that President Truman’s actions fell into the third category and were unconstitutional.

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