Justice Black for the majority of the Court rejected the notion that unchallenged emergency action by former Presidents provided any solid legal precedent for Truman’s seizure of the steel mills.[784] “The President’s power to issue the order must stem either from an act of Congress or from the Constitution itself.”[785] The seizure order could not be sustained by any of the constitutional grants of executive power to the President.[786] The President, rather than basing his order upon a specific statute, had chosen to direct “that a presidential policy be executed in a manner prescribed by the President.”[787] Black did not question “the power of Congress to adopt such public policies as those proclaimed by the order.” The action of the President in initiating such a policy was, however, an unconstitutional arrogation of “lawmaking power” to the executive.[788] Justice Black avoided citation of judicial precedent in that portion of his opinion which invalidated the President’s action. The reason for this is clear, and has been stated succinctly by Professor Edward S. Corwin in comments upon the _Steel Seizure_ cases: “The doctrine of the case, as stated in Justice Black’s opinion of the Court, while purporting to stem from the principle of separation of powers, is a purely arbitrary construction created out of hand for the purpose of disposing of this particular case, and is altogether devoid of historical verification.”[789] Each of the six justices who concurred in Black’s majority opinion in the _Steel Seizure_ cases stated his reasons in full.[790] By far the most lucid, best reasoned, and most adequate of any of the opinions appears to be that of Justice Jackson. He avoided the oversimplification of issues which weakens Black’s opinion. Filling the theoretical lacunae which Black in his hasty advance to the target (invalidation of Truman’s action) left in his wake, Jackson recognized that the real issue of the case was not that the President had taken emergency action unsupported by a declaration of legislative policy, but that his measures had been “incompatible with the expressed or implied will of Congress.”[791] Justice Jackson founded his opinion upon the concept of our government as a “balanced power structure.”[792] The Constitution disperses power among the branches of government, but contemplates that practice will achieve the integration essential to effective government. “Interdependence” rather than “separateness” is the relationship that must exist. The powers of a President in time of emergency are not, as the Government had argued, comprehensive and undefined; neither are they fixed, “but fluctuate, depending upon their disjunction or conjunction with those of Congress.”[793] Jackson enumerates alternatives of Presidential-Congressional relationships which may determine the extent of executive power: