Youngstown Sheet & Tube Co. v. Sawyer

The Court held that President Truman lacked authority to seize the nation's steel mills to avert a wartime strike.

Overview

Facing a nationwide steel strike during the Korean War in 1952, President Harry Truman ordered Commerce Secretary Charles Sawyer to take possession of the mills, citing his powers as commander in chief. Justice Hugo Black, for a 6-3 majority, held that no statute authorized the seizure and that the president's power to see laws faithfully executed did not make him a lawmaker. Justice Robert Jackson's concurrence set out three categories of presidential power, strongest when acting with Congress, uncertain in a zone of twilight, and at its lowest ebb when acting against the will of Congress. That framework remains the standard test for executive power disputes.