Youngstown Sheet and Tube Co.v. Sawyer Flashcards
Significance of the case
was a United States Supreme Court decision that limited the power of the President of the United States to seize private property
ignore
ignoere
How did President Truman deal with the steel companies and their unions?
Truman decided to seize their production facilities, while he kept the current operating management of the companies in place to run the plants under federal direction.
Facts Summarized pt. 1
During Korean War– steelworkers threatened to go on strike/shut down steel production. In 1950 congress passed the defense production act –> purpose to ensure the production of essential equipment during war + established wage stabilization board to broker solutions to labor disputes in war-related industries = was supposed to represent gov sitting down and negotiating settlement between workers and those who owned the factories
union demands rise, union agrees to post pone strike. Just before midnight when strike = meant to begin
President Truman issued executive ordered to transfer authority over steel mills to the government so weapons would continue being produced during time of war + to prevent a strike.
Congress took no action in response to the seizure
The companies challenged his power to take such action as being without constitutional authority or prior congressional approval.
enjoin
→ workers are not allowed to start a strike→ 80 day extension of whatever deal the workers were pissed about
Issue?
Did the President have the constitutional authority to seize and operate the steel mills?
Whether the president’s inherent powers derived from the vesting, take care, and commander in chief clauses authorize the temporary seizure of an essential industry during a time of war
How did the majority resolve the issues
strict construction + structuralism: would be undermining the consiution and seperation of powers by implying that executive can makes laws if needed
- President’s power must stem from either from an act of Congress or from the constitution itself → no law passed by congress that allows the pres to do this
- Is there an article of constitution/congress that allows the pres to do this → no
- there are statues that expressly authorizes the pres to take possession of property as he did here: - would have to provide just compensation → dely → strike taking place → either one would have required the gov to pay the much higher steel price the owners demanded → didn’t want this
- could use an enjoin, but what happens after 80 days
Can’t be the commender in chief clause → constitution –> being commander in chief means that you can tell generals where to invade + deligate troops, but it does not mean that in areas where there is not war you can tell steel mill owners that they aren’t in charge of their own property
can’t be the vesting or take care clasue*
- the nature of presidetential power = diff then consitutional power
- pres power = to see that the laws are faithfully executed refutes the idea that he is to be a lawmaker
Court Opinion by Black ignore
ignore
Concurring Opinion by Douglas
-implying → the fact that we are at war + steel mills = going to strike = does not create an instance for president’s power to grow, only one for congress to do it’s job
- seizure of plant = taking → must pay compensation
- pres cannot go around taking property
- Two Problems with this taking
- truman is not using any process laid out by congress
- the pres has no conisutional power to raise reenues on his own
- pres ⇒ not creating new executive powers during this emergency → pres does not get to do stuff that he does not usually get to do
Concurring Opinion by Jackson
Pragmatism
Think of presidential power as belonging to one of three categories
1. Maximum authority: pres acting in way that furthers an express or implied authorization of congress -> includes all his power + all that congress can delegate
2. The Zone of Twilight: pres acting in absence of congressional grant or denial of authority = can only depend on his own independent powers
3. Lowest Ebb: pres taking measures incompatible with expressed or implied powers of congress-> can only rely on his own constitutional powers of congress over a matter
Thinks jacksons arguments = in this category
Here, falls into 3rd category becuaes Taft Hartley Act shows Congress’s express opinion that President cannot seize land in a labor dispute. Unconcsitutional.
Dissent by Vinson
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Congressional Intent
- why are we trying to figure out what congress meant while passing a law written during peace time in the 1900s
- congress signed bill → treaty bound to fight war in korea → money = going to waste if in the middle of the war the stuff you need for guns, tanks etc → dissapears
- Appeal to pragmatism
- public use v. private use, just compensation v. not just
- gigantic taking → makes his action less scary
- the need for taking over a giant industry like this → barley happens → only happens in weird emergency scineros
- not bad that we’re expanding his power in this moment → will not happen often, only from time to time
- the need for taking over a giant industry like this → barley happens → only happens in weird emergency scineros
Appeal to history
- congress spent money fighting war → lets make sure the money set aside for steel is used effectively
- truman → giving congress an opportunity to act → asked them
Taft-Hartley Act:
Authorized president only to impose an 80-day cooling off period as a way to postpone any strike that seriously threatened the public interest.
Why did Truman not want to use the Taft Hartley Act?
did not want to use it because he vetoed it, unions opposed it + it’s main purpose of the law was to govern peace time labor disputes
Facts pt. 2
- Owners of steel mills take the secretary of commerce Charles Sawyer to Court
- Truman writes to congress explaining what he did and asks for further instructions
- Things congress could do: congres could authroize trumans actions and provide framework for gov management of the mills or congress could pass a law forbidding truman from doing what he did
- Truman writes the president again
- Case argued before Supreme court
- extremely fast pace
- 6/2/52: Supreme Court sides with steel owners
majority opinion → justice black
majority opinion → justice black: no, Truman’s actions do not constitute lawmaking
