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January 01, 2018

Learning Gateways: Youngstown Sheet and Tube Co. v. Sawyer Primary Source Jigsaw

In this activity, students study five primary sources related to the 1952 U.S. Supreme Court case, Youngstown Sheet and Tube Co. v. Sawyer. The landmark decision articulated limits to presidential power and outlined standards for analyzing presidential executive orders that are still in use by courts today.

Background: President Truman’s Executive Order 10340 & Youngstown Sheet & Tube Co. v. Sawyer

On December 18, 1951, collective bargaining between steel companies in the United States and their employees broke down and led to an announcement that the employees would strike on December 31, 1951. In an attempt to reach an agreement between the parties, the Federal Mediation and Conciliation Service intervened. Its efforts were unsuccessful and on April 4, 1952 the steel mill employees’ union gave notice of its intent to strike on April 9, 1952.

President Truman believed that a strike of any length would interfere with defense contractors and the domestic economy while the country was involved in the Korean War. Unable to mediate the differences between the union and the industry, President Truman issued an executive order on April 8, 1952 authorizing the U.S. Secretary of Commerce Charles Sawyer to take possession of and operate most of the nation’s privately owned steel mills. President Truman immediately informed Congress of his action and stated his intention to abide by the legislative will. However, Congress took no action.

The Steelworkers praised President Truman and postponed their strike while steel companies and most newspaper editorials opposed the steel mill seizures. The steel companies brought suit in federal court. A U.S. district court issued an injunction barring the government from continuing to hold the steel plants it had seized, which the U.S. court of Appeals stayed. Both the government and the steel companies petitioned the U.S. Supreme Court for certiorari. The Court heard the case and issued a decision on June 2, 1952.

Activity Procedure

1. Ask students to watch the first 2: 03 minutes of the Youngstown Sheet and Tube v. Sawyer Quimbee video and read the background handout.

2. Divide students into small groups and distribute one of the five primary source documents to each group. Ask each group to review their primary source and discuss the following questions:

  • What is your document?
  • What are the main points in your document?
  • How does your document relate to specific powers of branches of government, especially in relation to Truman’s executive order?

Selected questions specific to each primary source:

Executive Order 10340, April 8, 1952 (Primary Source 1)

  • What is the main reason President Truman provides for why the government is taking control of the steel mills?
  • According to President Truman, where does his authority to seize the steel mills come from?

Special Message to Congress, April 9, 1952 (Primary Source 2)

  • What is the tone of President Truman in this message to Congress?
  • What is the goal of Truman’s message to Congress?What action does he want Congress to take?

“Iron Fisted Breach,” the Knickerbocker News, April 23, 1952 (Primary Source 3)

  • What is being depicted in this political cartoon?
  • What do you think the cartoonist is trying to say about President Truman’s seizure of the steel mills?

Excerpts from Youngstown Sheet & Tube Co. et Al. v. Sawyer, decided June 2, 1952 (Primary Source 4)

  • According to the opinion of the Court delivered by Justice Black, where must the President’s power to issue this executive order come from?
  • According to the opinion of the Court, how has President Truman overstepped in his use of executive power?
  • How does the Court describe the role of Congress in comparison to the role of the president?

Excerpts from Special Message to Congress, June 10, 1952 (Primary Source 5)

  • What is the tone of President Truman in this message to Congress?
  • What action is President Truman asking Congress to take?
  • What other avenues has President Truman pursued to reach his goals in settling the issue with the steel mills?

3. After groups have had time to review their respective primary sources, ask them to share their source with the rest of the class. Through this share out students should begin to see the back and forth that President Truman goes through as he attempts to exert his presidential power and it is checked by Congress, the Supreme Court, and Congress again.

4. After the discussion it might be useful to ask the class to view the rest of the Youngstown Sheet and Tube v. Sawyer Quimbee video, which covers an analysis of the Court’s ruling and Justice Jackson’s concurring opinion. The concurrence outlined a framework for how the Court determines the limits of presidential powers.