Jackson analyzed both the history and purposes of the Articles of War to conclude that the Articles are not applicable to enemy combatants – rather, they were meant to protect U.S. civilians in times of military government. Although it would seem that his draft opinion is at odds with his later views of the President's war powers, specifically in "Youngstown Sheet & Tube Co. v. Sawyer" in which he interpreted Congress's ability to restrict the President's powers rather generously, there are substantive differences between the two cases. "Youngstown" concerned an exercise of presidential power in a domestic matter against civilians in an undeclared war. It was very different from the scenario present in "Quirin", in which the President seized enemy combatants and did not address the internal functioning of the government.