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Youngstown Sheet & Tube v. Sawyer, 343 US 579 (1952)

Probably the best known, and most controversial, case during Truman's Presidency was the 1952 appeal of Youngstown Sheet & Tube, et al., v. Sawyer, which dealt with Truman's attempt to seize steel manufacturers during the Korean War in order to avert a threatened strike by the United Steel Workers of America. Truman believed a strike would shut down production of military equipment and hamper the US war effort.

During previous wars, the government had successfully nationalized private industry, such as the railroads, telegraph system and Smith & Wesson Co., during WW I, and the railroads (again), coal mines, and trucking operations during WW II. In addition, Truman had seized 28 other properties and industries in 1945-46 to force settlement of labor disputes.

Truman authorized the seizure and government operation of most steel manufacturers on April 8, 1952, without consent of Congress. He also refused to invoke the Taft-Hartley Act, legislation passed in 1947 by a Congressional override of Truman's veto, that mandated an 8-day "cooling off period" during which embattled management and union representatives were supposed to negotiate a settlement.

Owners of the steel mills got a court injunction against the seizure, which the US appealed. The case was heard by the Supreme Court, which declared the President's actions unconstitutional on the grounds that Truman failed to cite any legislative authority permitting the President to exercise "emergency powers" without the consent of Congress.


Is this case still relevant?

Yes. Youngstown is commonly cited in cases where the President exceeds or appears to exceed the powers granted him (or her) by Article II of the Constitution. The basis of this case is whether the President had authority to exercise "emergency powers" without the consent of Congress, and hinges on the "separation of powers" doctrine.


Some recent cases citing Youngstown Sheet & Tube v. Sawyer, (1952)

US Supreme Court

Boumediene v. Bush, 553 US ___ (2008)
Hamdi v. Rumsfeld, 542 US 507 (2004)
Clinton v. City of New York, 524 US 417 (1998)
Clinton v. Jones, 520 US 681 (1997)

US Court of Appeals for the District of Columbia Circuit

Motion Systems Corp. v. Bush, 04-1428 (2006)

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Q: Is Youngstown Sheet and Tube v. Sawyer still relevant?
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