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Garcia v. San Antonio Metropolitan Transit Authority

Supreme Court of the United States · 1985 · Constitutional Law

federalismTenth AmendmentCommerce Clauseoverruling National League of CitiesCommerce ClauseTenth AmendmentfederalismFLSA

Facts

San Antonio's transit service began as a privately operated system, but the city purchased the system in 1959 and later transferred it in 1978 to SAMTA, a countywide public transit authority. SAMTA and its predecessor received substantial federal funding under the Urban Mass Transportation Act, with federal subsidies and local sales taxes accounting for about 75 percent of SAMTA's operating expenses. Congress had progressively extended the FLSA's minimum-wage and overtime requirements to state and local employees, including public mass-transit workers. After National League of Cities, SAMTA stopped paying FLSA overtime, and the Department of Labor later concluded that publicly owned local mass-transit systems were not immune from the Act.

Issue

May Congress, pursuant to the Commerce Clause, apply the FLSA's minimum-wage and overtime provisions to a municipally owned and operated mass-transit authority? More broadly, should National League of Cities' judicially enforced exemption for state activities involving 'traditional governmental functions' be retained?

Rule

The Commerce Clause permits Congress to apply generally applicable wage-and-hour regulations to state and local governmental entities, and the Constitution does not create a judicially enforceable immunity based on whether the regulated activity is a 'traditional' or 'integral' governmental function. The principal protection for state interests in this area lies in the political structure of the federal system, not in courts drawing substantive lines around protected state functions.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress amends a generally applicable federal wage-and-hour statute to require overtime pay for all employers engaged in economic activity affecting interstate commerce, including counties and cities. River County in Ohio refuses to comply for employees of its county-run ambulance service, arguing that emergency medical transport is a traditional local governmental function protected by the Tenth Amendment.

How should a court rule on River County's Tenth Amendment challenge?

Explanation. The majority rejected the "traditional governmental functions" inquiry as both unworkable and inconsistent with federalism. Under the Commerce Clause, Congress may apply generally applicable wage-and-hour rules to state and local entities, and a state cannot obtain immunity merely by labeling the regulated activity a traditional local function. The principal protection for state interests is the political structure of the federal system, not judicial line-drawing about which functions are sufficiently sovereign.