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Due to threats by the president to set import quotas, the U.S. State Department negotiated directly with European and Japanese steel producers to limit their companies' exports to United States. No foreign government was party to the agreement. Although the president has expressed authority to limit imports by an act of Congress, this act required that he either hold public hearings through the Tariff Commission about setting import quotas or deal directly with foreign governments about limiting imports. The Consumers Union of U.S., felt that when Congress gave the president this express power, it preempted any other action by the president. They brought an action against the secretary of state to have the president's agreement with private steel producers in Europe and Japan declared illegal. What should be the result of such an action? See 'Consumers Union of U.S., Inc. v Kissinger, 506 F.2d 136 (D.C. Cir. 1974).

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