Youngstown Sheet and Tube Co. v. Sawyer (1952) Definition

In this U.S. Supreme Court case, the Court ruled that President Truman didn't have statutory or constitutional authority to seize striking steel factories to assure a supply of steel for the war effort in Korea.

Today, Youngstown is best known for Justice Jackson's concurring opinion. In that opinion, Justice Jackson laid out a three-tiered approach to analyze challenges to executive power. When there's a challenge to the President's authority, courts try to place the President's action within one of these three categories:

  1. When the President acts with an express or implied congressional authorization, the President's power is at its greatest.
  2. When the President acts without a grant or denial of authority from Congress, the President's action must rest on the President's powers alone. In some circumstances, congressional silence might invite the President to act.
  3. When the President acts contrary to the expressed or implied will of Congress, the President's powers are at their lowest.