Memorandum, Summary and Analysis of Opinions in Steel Seizure Case (Youngstown Co. v. Sawyer)

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JLM 6/3/52 SUMMARY AND ANALYSIS OF OPINIONS IN STEEL SEIZURE CASE (YOUNOSTOWN co. V. SAWYER, Nos. 744 and 745) I SUMMARY OF OPINIONS Opinion of the Court by Mr. Justice Black (Concurred in by Justices Frankfurter, Douglas, Jackson and Burton. Justice Frankfurter ex- pressed some doubt as to the general principles stated, but agreed to their application to the circunstances of the case.) No statute expressly or by fair implication authorizes such a seizure as this. Indeed, "Congress had refused to adopt" the "use of the seisure technique to solve labor disputes.' When the Taft- Hartley Act was enacted, it was apparently "thought that the tech- nique of seizure, like that of compulsory arbitration, would inter- fere with the process of collective bargaining. The President's action cannot be sustained under his authority as Commander-in-Chief for "even though theatre of war! be an ex- panding concept, is the powers of the Commander-in-Chief do not include the power "to take possession of private property in order to keep labor disputes from stopping production. And the provisions granting executive power to the President do not empower him to be a lav maker. His present order does not direct execution of a congressional policy, it declares a presidential policy. The power of Congressto authorize such action is beyond dispute, but the President may not exercise leg- islative power. Opini on of Mr. Justice Frankfurter "We must put to one side consideration of what powere the President would have had if there had been no legislation whatever bearing on the authority asserted by the seizure, or if the seizure had been only for a short, explicitly temporary period, to be determined automatically unless Congressional approval were given." Congress has frequently legislated in this area, and in authorizing presidential seizures has carefully circumscribed the power by defining the circunstances in which it can be invoked, prescribing the duration of seizure and legislating with respect to compensation to be paid. In the Taft-Hartley Act Congress "decided against conferring [seizure power7

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