The Youngstown Sheet & Tube Co. v. Sawyer case in 1951, also known as the Steel Seizure Case, was a significant United States Supreme Court decision that limited the power of the President of the United States to seize private property. The case arose during the Korean War when steelworkers threatened to strike and halt production. In response, President Harry S Truman issued an executive order directing Secretary of Commerce Charles Sawyer to seize and operate most of America's steel mills in order to maintain war production. This action was challenged by owners who argued that it exceeded presidential powers under Article Two of Constitution. In a 6-3 decision led by Justice Hugo Black, the court held that while Congress may authorize such actions in times of emergency or war through legislation, there is no inherent executive power for this purpose without legislative approval - even during wartime conditions - thus making Truman’s seizure unconstitutional because he did not have Congressional authorization.

In the dissenting opinion for Youngstown Sheet & Tube Co. et al. v. Sawyer, Justice Harold Hitz Burton argued that President Truman's seizure of steel mills during a labor dispute was constitutional due to his inherent executive power and authority as Commander in Chief during wartime (the Korean War). He contended that the president had acted out of necessity to prevent a national emergency - an impending strike in the steel industry which would have severely impacted military production needed for war efforts. Furthermore, he believed Congress had implicitly approved such action by providing funds for war-related activities without restricting presidential powers over industrial disputes affecting defense production. Thus, according to Justice Burton, this case did not represent an unconstitutional overreach of executive power but rather a legitimate exercise thereof under extraordinary circumstances.