Property I, Pages 44–52

United Steel Workers v. United States Steel Corp.

United States Court of Appeals, Sixth Circuit, 1980

Facts:

Defendants own two steel mills the 3,500 plaintiffs work in. The defendants are planning on closing these mills, devastating the plaintiffs' economy. The defendants repeatedly and publicly announced for three years beforehand that they had no plans to close the mill, just to improve its productivity, and claimed that productivity had been improved sufficiently, partially by union deals that were less favorable to the workers.

Procedural History:

Defendants were initially convicted of violating the trespass statute.

Issue:

Can owners of a mill shut the mill down against the wishes of the workers?

Plaintiff's Arguments:

  • The defendants should not be able to close the mills when so many people depend on it. Especially after assuring those people that the mill would continue to exist, leading people to specially plan for such. This constituted promissory estoppel.

  • Being workers for so long historically, the plaintiffs have grown enough of a property right in the mills that they should be allowed to purchase them as they are.

Defendant's Argument:

The mills are unprofitable and there is no right of the workers to stop the defendants from closing them.

Rule:

Property rights require a legal basis to possess.

Reasoning:

  • Page 48

    ...none of the statements made by officers and employees of the company constituted a definite promise to continue operation of the plants if they did become profitable.

  • Page 48

    ...the statements relied upon by plaintiffs were made by employees and public relations officers of the company and not by company officers.

  • Page 48

    The condition precedent of the alleged contract and promised profitability of the Youngstown facilities was never fulfilled, and the actions in contract and for detrimental reliance cannot be found for plaintiffs.

Holding:

No, no evidence has been presented that could facilitate that.