Garcia v. San Antonio Metro. Transit Authority

Conclusion

In a 5-to-4 decision, the Court held that the guiding principles of federalism established in National League of Cities v. Usery were unworkable and that SAMTA was subject to Congressional legislation under the Commerce Clause. The Court found that rules based on the subjective determination of "integral" or "traditional" governmental functions provided little or no guidance in determining the boundaries of federal and state power. The Court argued that the structure of the federal system itself, rather than any "discrete limitations" on federal authority, protected state sovereignty.

Judgement

5-4 for Garcia

Occonors Dissent

Acknowledging that the changes in the national economy in the past two hundred years had transformed Congress' Commerce Clause power from being a marginal power that served mostly to mediate between the states by eliminating interstate tariffs and other burdens on interstate commerce into a general power that gave Congress essentially unlimited power to regulate in every area of economic life, O'Connor argued for special limitations on this power to protect the states' authority over their own employment relations. She invoked the limiting language of the most expansive interpretations of the Commerce Clause in the Court's decisions of the 1930s and 1940s to argue that the Court retained the power to decide whether a particular exercise of the Commerce Clause authority was necessary and proper to the federal purposes to be achieved. Applying that standard, she, joined by Justices Powell and Rehnquist, would find the FLSA unconstitutional as applied to employees of state and local governments.

Holding

Congress had the authority under the Commerce Clause of the United States Constitution to apply the Fair Labor Standards Act to a municipal mass transit system operated by a governmental entity. District Court for the Western District of Texas reversed.

Issues

Did principles of federalism make the San Antonio Metropolitan Transit Authority immune from the Fair Labor Standards Act?

Powells Disstent

Justice Powell, joined by Chief Justice Burger, Justice Rehnquist and Justice O'Connor objected to both the Court's failure to grant stare decisis effect to its earlier decision in National League of Cities and for reducing the balancing test that the Court adopted in National League of Cities into a cruder categorical distinction between traditional and non-traditional governmental functions. Powell's opinion was even more critical of the majority's failure to recognize any limiting role of the Tenth Amendment to the United States Constitution, accusing it of negating the Court's role in mediating between the two through judicial review of the constitutionality of Congress' intrusions into areas previously left to the states. Powell wrote "The State's role in our system of government is a matter of Constitutional law, not legislative grace."

Rehnquist Dissent

Justice Rehnquist expressed reservations as to Justice Powell's description of the standard actually adopted by the Court in National League of Cities and of the alternative standard proposed by Justice O'Connor, but reiterated his support of both dissenting opinions based on their opposition to the Court's resolution of those constitutional issues in this case.

Argument for San Antonio metro transit authority

National league of cities v usery established precedent that state power to determine wages and hours is an attribute of state sov. In this case, the very same act that threatened state sov in national league is again in question. The 10th amendment protects this transit is a traditional trade function because it is purely local, has a long history of state and local regulation through their power to regulate street transportation, and historically has not been subject to federal regulation any more than any of the activities protected in national league the transit system is indistinguishable from the hospitals that were exempted from federal regulation in the national league. both have roots in the private sector and both receive significant funding from the gov the fed gov is really making an argument about its spending power, not its commerce power clause. It is clear from national league that federal funding is irrelevant in determining whether an activity is protected

Facts

The San Antonio Metropolitan Transit Authority (SAMTA), the main provider of transportation in the San Antonio metropolitan area, claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act. SAMTA argued that it was providing a "traditional" governmental function, which exempted it from federal controls according to the doctrine of federalism established in National League of Cities v. Usery (1976). Joe G. Garcia, an employee of SAMTA, brought suit for overtime pay under Fair Labor Standards Act.

Arguments for Garcia

Transit is not a traditional gov function; instead it is traditionally a private business enterprise that has always been subject to federal labor regulation.Exempting state run transit systems from regulation because of the tenth amendment would encourage state takeover of all transity systems in order to avoid regulation. That is clearly not intended in the purpose of the 10th amendment National league of cities v usery limits federal authority only to the extent necessary to presere state sovereignty in essential state funcitons. State sov. is most directly expressed in lawmaking and law enforcement powers, not in the states provision of particular goods and services. In this case, the provision of service is in question, not law making or law enforcement powers funding from the fed gov made possible the states entry into the public transity arena. Therefore the public transit systems are cooperative efforts of the fed gov and the state. It would be illogical to conclude that the very federal aid that helped create this system is not subject to federal regulation