Garcia v. San Antonio Metropolitan Transit Authority

Brief Fact Summary.

The San Antonio Metropolitan Transit Authority challenged the minimum-wage and overtime requirements of the Fair Labor Standards Act arguing that Congress may not regulate State’s matter that solely belong to the State.

Synopsis of Rule of Law.

Four conditions must be satisfied before a state activity may be deemed immune from a particular federal regulation under the Commerce Clause. First, the federal statute must regulate the States as States. Second, the statute must address matters that are indisputably attributable of state sovereignty. Third, state compliance with the federal obligation must directly impair the States; ability to structure integral operations in areas of traditional governmental functions. Finally, the relation of state and federal interests must not be such that the nature of the federal interest justifies state submission.

Facts.

In National Leagues of Cities v. Usery, the Court held that the Commerce Clause does not empower Congress to enforce the minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA) against the States in areas of traditional governmental functions. Though the case supplied some examples of traditional governmental functions, it did not offer a general explanation of how a traditional function is to be distinguished from a non-traditional one. In the current case, a federal district court concluded that municipal ownership and operation of a mass-transit system is a traditional governmental function and thus, under National League of Cities, is exempt from the obligations imposed by the FLSA.

Issue.

May Congress enforce the minimum wage and overtime provisions of the Fair Labor Standards Act against the States in areas of municipal ownership and operation of a mass-transit system?

Held.

Yes, because nothing in the overtime and minimum-wage requirements of the Fair Labor Standards Act, as applied to the San Antonio Metropolitan Transit Authority (SAMTA), that is destructive of state sovereignty or violative of any constitutional provision. SAMTA faces nothing more than the same minimum-wage and overtime obligations that hundreds of thousands of other employers, public and private, have to meet. Consequently, the State authority, SAMTA, must comply with the provisions of the federal statute at issue.

Dissent.

Justice Powell

The majority’s opinion does not explain how the States’ role in the electoral process guarantees that particular exercises of the Commerce clause power will not infringe on residual State sovereignty. Members of Congress are elected from the States, but once in office, they are members of the federal government. The majority’s opinion also reflects the Court’s unprecedented view that Congress is free under the Commerce Clause to assume a State’s traditional sovereign power and to do so without judicial review of its action.

Discussion.

The States unquestionably retain a significant measure of sovereign authority. However, such authority extends only to the extent that the Constitution has not divested them of their original powers and transferred those powers to Congress. If the power was not given, Congress could not exercise it to interfere with the power of the States; if given, they might exercise it but should not interfere with the Constitution. It is true that the States occupy a special and specific position in our constitutional system and that the scope of Congress’ authority under the Commerce Clause must reflect that position. But the principal and basic limit on the federal commerce power is that inherent in all congressional action. Congress does have the authority to require the minimum-wage and hours in San Antonio through the federal statute, which does not unduly burden the State. Thus, FLSA is constitutional.