## Facts

- United States Steel Corporation operated two major steel mills in Youngstown, Ohio (Ohio Works and McDonald Works), employing roughly 3,500 workers when closure notice was given.
- The facilities were aging and increasingly obsolete, and U.S. Steel concluded they were unprofitable under ordinary business/accounting standards.
- U.S. Steel announced plans to shut down the mills, prompting claims that closure would severely harm workers, families, and the local economy.
- Local unions and individual workers alleged U.S. Steel representatives had encouraged productivity and profitability improvements and implied the mills would remain open if made profitable.
- Plaintiffs sought injunctive and related relief to prevent closure and, alternatively, to require a sale to a proposed community-controlled entity.
- The district court found the mills unprofitable, rejected contract, promissory estoppel, and “community rights” theories, and entered judgment for U.S. Steel.
- Plaintiffs appealed.

## Issues

1. Whether statements and conduct by U.S. Steel created an enforceable contract to keep the mills open, or supported promissory estoppel barring closure.
2. Whether employees or the community possessed a legally cognizable property-type interest in continued operation of the mills that could justify judicial compulsion.
3. Whether U.S. Steel’s refusal to sell the mills to a community buyer could violate federal antitrust law.

## Decision

- The Sixth Circuit affirmed rejection of the contract claim, holding plaintiffs failed to show a binding agreement requiring continued operation.
- The Sixth Circuit affirmed rejection of promissory estoppel, concluding the alleged assurances were not definite, unconditional promises, and any “remain open if profitable” condition was not satisfied.
- The Sixth Circuit affirmed rejection of the “community/property right” theory, concluding existing law did not recognize a property right in continued employment or continued operation of a private plant.
- The Sixth Circuit vacated and remanded on a limited antitrust question concerning whether refusal to sell to a community entity could constitute an antitrust violation.

## Legal Principles

- Absent a valid contract or a definite promise satisfying promissory estoppel requirements, courts will not compel a private corporation to continue operating a facility after a business decision to close for unprofitability.
- Promissory estoppel requires a clear, definite promise; generalized managerial statements and conditional assurances tied to unmet profitability do not create enforceable obligations.
- Economic dependence of workers or a municipality on a private employer does not, by itself, create a legally enforceable property interest in continued employment or continued plant operation.
- Broad policy responses to plant closings are primarily for legislative bodies; courts generally may not create new rights to force continued industrial operations.
- Antitrust law may, in certain circumstances, constrain conduct surrounding closure or sale decisions; where adequately alleged and undeveloped, such claims may require further proceedings.

## Conclusion

The court held that severe community and worker harm from a plant closing does not authorize judicially compelled operation without an enforceable contract or definite promise, while leaving open on remand a narrow possibility of relief under federal antitrust law based on an alleged refusal to sell.


Local 1330, United Steel Workers of Am. v. U.S. Steel Corp., 631 F.2d 1264 (6th Cir. 1980)