that the Court not only relied on the express wording of the Constitution but also carefully examined the legislative history of the Taft-Hartley Act. As Justice Frankfurter said in his concurring opinion, it found that not only did Congress not intend to confer such power on the President but expressed a contrary intent. In his concurring opinion Justice Jackson stated that separation of powers issues often involve an interpretation of overlapping or concurrent powers, a twilight zone in which the Constitution "enjoins upon its branches separateness but [also] interdependence, autonomy but reciprocity." However, Justice Jackson did not find Truman's action to be within that twilight zone but rather that it was an example of unwarranted exercise of arbitrary executive power.
In cases where the Congress has impliedly sanctioned an exercise of power by the executive, the Court has tended to uphold it even where explicit support for it in the language of the Constitution is lacking. This has been particularly true in the area of foreign relations which is largely but not entirely the province of the executive. In Dames & Moore v. Regan, 453 U.S. 654 (1981), the Court upheld Presidential Executive Orders which were issued to settle the Iranian hostage crisis, set up a Claims Tribunal to settle disputes involving the United States
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