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Maryland v. Wirtz

Supreme Court of the United States · 1968 · Constitutional Law

Constitutional LawCommerce ClauseFederalismFair Labor Standards ActCommerce ClauseFLSAenterprise conceptstate sovereignty

Facts

The Fair Labor Standards Act originally covered employees individually engaged in commerce or the production of goods for commerce and excluded States and their political subdivisions from the definition of employer. In 1961 Congress adopted the "enterprise" concept, extending coverage to all employees of an enterprise engaged in commerce if the enterprise met statutory criteria, and in 1966 Congress added hospitals, schools, and similar institutions to the covered enterprise categories regardless of whether they were public or private. Congress also removed the States' employer exemption with respect to employees of those hospitals, institutions, and schools. The plaintiff States challenged these amendments as beyond the commerce power, violative of state sovereignty and the Eleventh Amendment, and argued that schools and hospitals did not have the statutory connection to commerce required for coverage.

Issue

Whether Congress, under the Commerce Clause, could constitutionally extend the Fair Labor Standards Act through the enterprise concept and apply it to state-operated schools and hospitals. Also, whether the Court should invalidate the Act based on possible Eleventh Amendment problems or declare in the abstract that schools and hospitals lack employees engaged in commerce within the meaning of the statute.

Rule

Congress may regulate intrastate activities where it has a rational basis for finding that the regulated class of activities substantially affects interstate commerce. Once Congress rationally defines a class of activities affecting commerce, courts do not excise trivial individual instances within that class, and valid general regulations of commerce do not become invalid merely because the regulated enterprise is operated by a State rather than a private party.

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

Congress amends a federal wage-and-hour statute to cover every employee of any urban laundry enterprise that has at least one worker ordering detergent and replacement parts from out-of-state suppliers. The statute applies to both nonprofit and for-profit laundries. Lakeview Linen, a private laundry in Milwaukee, argues that its bookkeepers and janitors cannot be regulated because they never touch goods moving across state lines.

Under the majority's reasoning, is Lakeview Linen's argument likely to succeed?

Explanation. The majority upheld the enterprise concept because Congress may regulate a broader class than only those employees physically connected to interstate goods. It was enough that Congress had a rational basis for concluding that labor conditions across an interstate enterprise affect competition and commerce. Courts do not require direct interstate activity by each covered worker, and the Court said it was irrelevant whether Congress compiled new detailed findings in any particular form.