Garcia v. San Antonio Metropolitan Transit Authority

Brief Fact Summary.

The San Antonio Metropolitan Transit Authority argued that the minimum-wage and overtime requirements of the federal Fair Labor Standards Act which states that Congress may not regulate State’s matter that solely belong to the State violate the Constitution.

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, it is said that the federal statute must regulate the States as States. Second, the statute must address matters that are indisputably attributes of state sovereignty. Third, state compliance with the federal obligation must directly impair the State’s 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 League of Cities, the Court ruled 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 National League of Cities 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 nontraditional case. Since then, federal and state courts have struggled with the task, thus imposed, of identifying a traditional function for purposes of state immunity under the Commerce Clause. A Federal District Court concluded that municipal ownership and operation of a mass-transit system is a traditional governmental function and thus 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, there is nothing in the overtime and minimum-wage requirements of the FLSA 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 as well as private, have to meet. Thus, the San Antonio Metropolitan Transit Authority must comply with the federal statute.a

Dissent.

Justice Powell and Rehnquist

Powell: The Court 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.

Rehnquist: Due to the emergence of an integrated and industrialized national economy, the Court has been required to examine and review a breathtaking expansion of the powers of Congress. The Constitution, however, is animated by an array of intentions. A conflict has now emerged, and the Court today retreats rather than reconcile the Constitution’s dual concerns for federalism and an effective commerce power.

Discussion.

The States unquestionably do retain a significant measure of sovereign authority. They do so, however, only to the extent that the Constitution has not divested them of their original powers and transferred those powers to the Federal Government. The Constitution does not carve out express elements of state sovereignty that Congress may not employ its delegated powers to displace. The power of the Federal Government is a power to be respected as well, and the fact that the States remain sovereign as to all powers not vested in Congress or denied them by the Constitution offers no guidance about where the frontier between state and federal power lies. The principal means chosen by the Framers ensure the role of the States in the federal system lies in the structure of the Federal Government itself. It is no novelty to observe that the composition of the Federal Government was designed in large part to protect the States from overreaching by Congress. The effectiveness of the federal political process in preserving the States’ interests is apparent today in the course of federal legislation. The States have been able to direct a substantial proportion of federal revenues into their own treasuries in the form of general and program-specific grants in aid. Also, that the States have exercised their influence to obtain federal support, they have been able to exempt themselves from a wide variety of obligations imposed by Congress under the Commerce Clause.