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Garcia v. San Antonio Metropolitan Transit Authority

    Brief Fact Summary. Congress enacted a statue, which regulated minimum wage and overtime provisions applicable to all businesses of a certain size. The statute contained no exemption for employees of state-owned mass transit systems.

    Synopsis of Rule of Law. The Tenth Amendment provides that “the powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the People.” This Amendment places a small but significant limit on Congress’ ability to use the commerce power to regulate states.

    Facts. Fair Labor Standards Act (FLSA) imposed minimum wage and overtime provisions against States. The Court ruled in National League of Cities v. Usery that FLSA’s requirements could not be applied constitutionally to the “traditional governmental functions” of state and local governments. This case had the same fact pattern as National League of Cities

    Issue. Should the Court follow the law in National League of Cities? If not, does the Tenth Amendment limit Congress’ Commerce power?

    Held. Justice Blackmun. No to both questions. District Court judgment is reversed and the case is remanded to that court for further proceedings.
    National League of Cities provided some examples of “traditional governmental functions” but it did not offer a general explanation of how a “traditional” function is to be distinguished from a “nontraditional” one. Confining immunity based on the historical, non-historical or necessary governmental services would lead to inconsistent results, is unworkable, and is inconsistent with established principles of federalism. Federalism requires that states have free access to engage in any activity that their citizens choose for the common weal.
    The Court decided that the structure of the federal government itself insulates the interests of states from federal encroachment. A Senate that is made up of states will be disinclined to invade the rights of the individual states or the prerogatives of their governments. The process ensures that laws that unduly burden the states will not be promulgated.
    The extent of the sovereign powers is governed by the United States Constitution. A variety of sovereign powers are withdrawn from the states and Congress can exercise a wide range of legislative powers to displace contrary state legislation. The sovereign authority that states retain is only to the extent that the Constitution has not divested them of their original powers or transferred those powers to the Federal Government.

    Dissent. Justice Powell, The Chief Justice, Rehnquist, and Justice O’Conner dissent. This was a 5-4 decision.
    National League of Cities was reiterated consistently over the past eight years. The principle of stare decisis and the rationale of recent decisions were ignored abruptly in this case. J. O’Conner states that it was difficult to craft bright lines defining the scope of the state autonomy protected by National League of Cities.
    The majority opinion does not explain how the state’s role in the electoral process guarantees that particular exercises of the Commerce Clause power will not infringe on residual state sovereignty. There is no explanation as to why Congress will not seek to invoke its power under the Commerce Clause notwithstanding the electoral role of the States.
    If the balancing test had been completed, then the Court would find that the federal interest is not demonstrably greater than the state interest.

    Discussion. A narrow reading of this case is that when Congress enacts a generally applicable law, then the fact that the regulation affects the state has almost no significance. A broad reading of the case is that states are not as protected against encroachment by the federal government as they once were. Unlike market participant exceptions as there were in Reeves and White for interstate commerce cases, the Court has overruled the protection that National League of Cities gave states in setting affirmative limits on the Commerce power when federal regulation directly impairs a state’s ability to perform integral operations that were traditionally under state control.


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