## Facts

- United States Steel Corporation operated the Ohio Works (since 1901) and McDonald Works (since 1918) steel plants in the Youngstown, Ohio area under collective bargaining agreements with United Steelworkers locals.
- By the late 1970s, the plants were viewed as obsolete due to aging equipment and changes in steelmaking technology and markets.
- U.S. Steel decided to permanently close both plants, affecting roughly 3,500 employees.
- The union locals, individual workers, and community members alleged the shutdown would cause severe economic harm to employees and the surrounding community.
- Plaintiffs asserted U.S. Steel had made oral and implied assurances to keep the plants operating so long as they were profitable, and that workers relied on those assurances.
- Plaintiffs sought injunctive relief requiring U.S. Steel to keep the plants open and operating (or to prevent closure).

## Issues

1. Whether a federal court may compel a private corporation to continue operating plants after corporate management decides to close them based on unprofitability.
2. Whether employees or the surrounding community have a legally cognizable property right in continued employment or continued plant operation that supports injunctive relief.
3. Whether alleged promises about continued operation created enforceable contract or promissory estoppel rights sufficient to require the plants to remain open.

## Decision

- The court denied injunctive relief and refused to order U.S. Steel to continue operating the plants.
- The court held it lacked constitutional, statutory, or common-law authority to force a private corporation to keep operating facilities against the decision of its officers and board.
- The court rejected the claim that workers or the community possessed a general property right to continued employment or to the continued operation of the plants.
- The court concluded the alleged assurances regarding continued operation were not sufficiently definite or enforceable to support contract or promissory estoppel relief compelling ongoing operations.
- The court stated that policy choices about regulating plant closings are for legislatures, not courts.

## Legal Principles

- Absent specific legal authorization, federal courts cannot compel a private corporation to continue business operations after a management decision to close facilities.
- In private employment, continued employment or continued plant operation is not a general property right enforceable by injunction without a specific statutory or contractual basis.
- General or conditional management statements about future operations typically do not create enforceable obligations to keep a facility open; promissory estoppel will not be extended to mandate continued industrial operations.
- Broad regulation of plant closings and related public policy is primarily a legislative function rather than a matter for judicial creation of new rights or duties.

## Conclusion

The court refused to prevent the shutdown of U.S. Steel’s Youngstown-area plants, holding it had no authority to require continued operations and that plaintiffs lacked an enforceable property, contract, or promissory estoppel right to continued employment or plant operation.


United Steelworkers of Am., Loc. No. 1330 v. United States Steel Corp., 492 F. Supp. 1 (N.D. Ohio 1980)