Youngstown Sheet & Tube Co. v. Sawyer

In late 1951, steel-mill owners and their employees had disagreements over the terms of collective-bargaining agreements. Unable to reach an agreement, the steel-mill employees’ representative gave notice of intent to strike after the expiration of their current agreement. The federal government unsuccessfully entered the negotiations, and on April 4, 1952, the steel-mill employees’ union gave notice of its intent to strike on April 9, 1952. The importance of steel as a component in weapons and war materials led President Truman to believe that a reduction in steel production from a nationwide strike would jeopardize the nation’s security. The president issued Executive Order 10340 directing Sawyer (defendant), the secretary of commerce, to take control of and continue operating most of the nation’s steel mills. Sawyer carried out the order, and Youngstown Sheet & Tube Co. (plaintiff), along with other steel-mill operators, brought suit in district court alleging that the president’s order amounted to an exercise of lawmaking, a legislative function reserved expressly for Congress. Therefore, the president’s exercise of lawmaking was unconstitutional. The district court granted an injunction in favor of the Youngstown Sheet & Tube Co., on the grounds that the president acted unconstitutionally, but the court of appeals stayed the injunction. The United States Supreme Court granted certiorari.