National League of Cities v. Usery

Brief Fact Summary. The Appellants, National League of Cities (Appellants), brought suit challenging the constitutionality of the 1974 amendments to the Fair Labor Standards Act (the Act), specifically the requirement that state governments pay their employees the new minimum wage and overtime.

Synopsis of Rule of Law. The Tenth Amendment of the United States Constitution (Constitution) acts to preserve the States’ sovereign authority and limit the Congress’ power to compel State actions.

Facts. In 1974, Congress amended the Act to, among other things, apply the Act’s provisions to public employers. Appellants allege that the requirements of the amendments will greatly increase the cost of operating state governments to the extent that the governments will require greater income or provide decreased public services. Appellants also argue that Congress has intruded upon powers left to the States in so amending the Act.

Issue. May Congress regulate the employment practices of state governments?

Held. No. Reversed and remanded. Justice William Rehnquist (J. Rehnquist) states that the Act would require states to substantially restructure traditional ways in which they have operated. He argues that this is a power reserved to the States and that to force States to comply with Congress’ view of how they should operate their traditional affairs destroys the States’ separate and independent existences.

Dissent. Justice William Brennan (J. Brennan) believes that the United States Supreme Court (Supreme Court) has erred in saying that the Constitution refers to the states’ sovereignty acting as a restraint on Congress’ commerce power and the political process allows the states to deal with such issues.
Justice John Paul Stevens (J. Stevens) notes that the federal government may require the states to obey a vast number of regulations, in the midst of which a state’s right to pay employees a substandard wage is difficult to discern.
Concurrence. Justice Harry Blackmun (J. Blackmun) does not see the ruling in this case as outlawing federal power in forcing states to comply with environmental regulations and other such areas where the “federal interest is demonstrably greater.”

Discussion. National League of Cities v. Usery is the first attempt by the modern Supreme Court to establish a jurisprudence of state sovereignty based on the text of the Tenth Amendment of the Constitution.