YOUNGSTOWN SHEET & TUBE CO. VS SAWYER : CASE SUMMARY
The Supreme Court in Youngstown Sheet & Tube Co. Vs. Sawyer (1952) held that President does not have any authority to acquire private property without approval of Congress during National Emergency.
FACTS OF THE CASE
This case was determined during Korean War. Steel was important input for war materials as such steel industry was critical during war time. Disputes were going on between Steel Company owners and workers over wages and other issues. Fear of strike was looming large. President Truman decided to take control of steel mills for ensuring production of steel without any hindrance. The President issued executive order to seize and operate steel mills.
The steel companies was shocked by this step of the President and filed suits which finally reached to the Supreme Court.
OPINION OF THE SUPREME COURT
It was argued by the Government that in wartime the President is empowered to take emergency measures without approval of the Congress as the President is Commander-in-Chief of the armed forces and he is liable for defense of the Country.
On the other hand, it was argued by the Petitioners that the President has no power to issue executive order even during emergency. Only the Congress has power to make laws regarding economy and labor disputes.
The Supreme Court held that the President was not having any power to issue such executive order. Power to issue such order should either stem from the Constitution or from laws passed by Congress. President has no inherent powers other than enumerated in the Constitution.
As commander-in-chief, the President does have broad military powers but this does not extend to domestic economic regulation.
Justice Jackson delivered a concurring opinion which provides a framework to test constitutionality of executive actions. He indicated three categories of executive actions. Firstly, where President acts under direct authorization of the Congress. Such actions are constitutionally valid. Secondly, President acts in sphere where there is absence of any authority of Congress. In such cases, the actions of President can be validated or invalidated depending on circumstances. Thirdly, President acts in contradiction to will of Congress. Such actions are invalid.
DISSENTING OPINION OF JUSTICE VINSON
Dissenting Opinion was delivered by Justice Vinson. Justice Vinson was of the view that President should be given greater discretion during emergency. Truman’s executive order was justified as national interest was involved in steel production during Korean War
IMPACT OF THE JUDGMENT
Youngstown Sheet & Tube Co. Vs. Sawyer is a landmark judgment in constitutional sphere. It emphasized separation of powers among executive, legislature and judiciary. The judgment delimits powers of the President. Even during emergency President has no inherent powers and has to act within the Constitutional framework and according to laws passed by the Congress.
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Mukesh Kumar Suman is an advocate and legal author based at Delhi. He regularly appears before various Judicial Forums including NCLT, NCLAT, High Courts and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.