Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985)
States may be immune from federal regulation under the Commerce Clause if the regulation destroys state sovereignty when it is applied to the state activity, or if it otherwise violates the Constitution.
The Wage and Hour Administration of the federal Department of Labor determined that the San Antonio Metropolitan Transit Authority was subject to the minimum wage and overtime requirements of the Fair Labor Standards Act. Seeking a declaratory judgment, SAMTA argued that it was immune from the FLSA requirements because its activities were related to a traditional governmental function, based on the test articulated in the Supreme Court decision in National League of Cities v. Usery (1976). Midway through the appeals process, the Supreme Court ruled in a different case that providing a commuter rail service is not a traditional governmental function, so it was not insulated from compliance with congressional regulations under the Commerce Clause. However, when the case was remanded to the trial court for further consideration on this basis, the trial court maintained its earlier view and entered judgment for SAMTA.Opinions
- Harry Andrew Blackmun (Author)
- William Joseph Brennan, Jr.
- Byron Raymond White
- Thurgood Marshall
- John Paul Stevens
The precedent in National League of Cities v. Usery is untenable because it provides a standard that cannot be consistently implemented, which requires courts to consider whether the federal regulation infringes on traditional governmental functions of the state. There was no guidance in that decision for courts to separate traditional governmental functions from others. As a result, lower courts have reached many clashing conclusions in this area based on illusory distinctions. Simply determining whether a governmental function is traditional based on whether or not it is historical does not suffice, since this allows no way to accommodate the evolution of state governments over time. States are allowed to conduct any governmental function that the Constitution does not withhold from them, and courts should not impose determinations of which functions are more important than others on the states. The Commerce Clause in Article I does not remove all protections for the states from federal regulation. States receive substantial influence over the federal legislative and executive branches through the structure of Article I and the federal government. Complying with requirements such as the FLSA minimum standards does not undermine the procedural protections on state sovereignty or violate any other part of the Constitution. National League of Cities is thus overruled.
- Lewis Franklin Powell, Jr. (Author)
- Warren Earl Burger
- William Hubbs Rehnquist
- Sandra Day O'Connor
The Framers of the Constitution sought for the states to retain sovereignty in some areas, and the majority undermines their intent by allowing Congress to take over the sovereign power of a state without judicial review. The electoral process does not provide an adequate safeguard for the states to protect their sovereignty.
- William Hubbs Rehnquist (Author)
Both of the dissents take a better approach than the majority, and either of them would lead to affirming the lower court decision.
- Sandra Day O'Connor (Author)
- Lewis Franklin Powell, Jr.
- William Hubbs Rehnquist
The Court has trended toward offering states fewer protections from Congressional action than they once enjoyed, although this case also can be interpreted as simply validating the right of the federal government to create general requirements that happen to affect the states.
U.S. Supreme CourtGarcia v. San Antonio Transit Auth., 469 U.S. 528 (1985)
Garcia v. San Antonio Transit Authority
Argued March 19, 1984
Reargued October 1, 1984
Decided February 19, 1985*
469 U.S. 528
Appellee San Antonio Metropolitan Transit Authority (SAMTA) is a public mass transit authority that is the major provider of transportation in the San Antonio, Tex., metropolitan area. It has received substantial federal financial assistance under the Urban Mass Transportation Act of 1964. In 1979, the Wage and Hour Administration of the Department of Labor issued an opinion that SAMTA's operations are not immune from the minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA) under National League of Cities v. Usery, 426 U. S. 833, in which it was held that the Commerce Clause does not empower Congress to enforce such requirements against the States "in areas of traditional governmental functions." Id. at 426 U. S. 852. SAMTA then filed an action in Federal District Court, seeking declaratory relief. Entering judgment for SAMTA, the District Court held that municipal ownership and operation of a mass transit system is a traditional governmental function, and thus, under National League of Cities, is exempt from the obligations imposed by the FLSA.
Held: In affording SAMTA employees the protection of the wage and hour provisions of the FLSA, Congress contravened no affirmative limit on its power under the Commerce Clause. Pp. 469 U. S. 537-557.
(a) The attempt to draw the boundaries of state regulatory immunity in terms of "traditional governmental functions" is not only unworkable but is also inconsistent with established principles of federalism and, indeed, with those very federalism principles on which National League of Cities purported to rest. That case, accordingly, is overruled. Pp. 469 U. S. 537-547.
(b) There is nothing in the overtime and minimum wage requirements of the FLSA, as applied to SAMTA, that is destructive of state sovereignty or violative of any constitutional provision. The States' continued role in the federal system is primarily guaranteed not by any externally
imposed limits on the commerce power, but by the structure of the Federal Government itself. In these cases, the political process effectively protected that role. Pp. 469 U. S. 547-555.
557 F. Supp. 445, reversed and remanded.
BLACKMUN, J., delivered the opinion of the Court, in which BRENNAN, WHITE, MARSHALL, and STEVENS, JJ., joined. POWELL, J., filed a dissenting opinion, in which BURGER, C.J., and REHNQUIST and O'CONNOR, JJ., joined, post, p. 469 U. S. 557. REHNQUIST, J., filed a dissenting opinion, post, p. 469 U. S. 579. O'CONNOR, J., filed a dissenting opinion, in which POWELL and REHNQUIST, JJ., joined, post, p. 469 U. S. 580.