Garcia v. San Antonio Metropolitan Transit Authority

Citation. 469 U.S. 528, 105 S.Ct. 1005, 83 L.Ed.2d 1016 (1985)

Brief Fact Summary.

After the Court’s decision in National League of Cities, the San Antonio Transit System no longer adhered to the FLSA.  Garcia sued for overtime pay.

Synopsis of Rule of Law.

States’ interests are protected by the overall framework of the federal government which provides for State participation.  Therefore, if the Commerce Clause authorizes Congress to act, the Tenth Amendment does not serve as an independent limitation on congressional powers.

Facts.

In National League of Cities v. Usery, 426 U.S. 833 (1976), the Court held that Congress, under its Commerce Clause powers, could not enforce the Fair Labor Standards Act’s (FLSA) minimum-wage and overtime provisions against the States in “areas of traditional governmental functions.”  The holding was based in part on the Tenth Amendment, which was interpreted as a barrier protecting State autonomy from congressional overreaching.  After National League of Cities, employees for the San Antonio Transit System were no longer given the overtime pay that the FLSA required.

Issue.

(1) Whether the Court’s interpretation of the Tenth Amendment in National League of Cities should be reconsidered.

(2) If so, how is State autonomy protected from Congress’ Commerce Clause powers?

Held.

JUSTICE BLACKMUN holding:

(1) Yes, the Court’s holding in National League of Cities proved unworkable.

(2) State’s are protected from congressional overreaching through “the structure of the Federal Government itself.”  States, through the political processes, participate in electing federal representatives.  This framework is sufficient to protect States, so judicially created barriers are unnecessary.

Dissent.

Justice Powell

Justice Powell dissented from the majority, reasoning that the majority departed from stare decisis and made the Tenth Amendment “meaningless.”  Further, as the media has become more nationally focused and local political parties have weakened, Congress has become less responsive to State interests.  The Court should have stepped in to protect the States because Congress will not limit its own power.

Justice Rehnquist

The Chief Justice wrote separately to express that National League of Cities should have been affirmed, and he expected that the Court would soon reaffirm its decisions under the Tenth Amendment doctrine.

Justice O’Connor

Justice O’Connor argued that the proper way to protect “state autonomy” against Congress’ Commerce Clause powers is to ensure that States are being treated as States, not like private parties.

Discussion.

The O’Connor plurality rejected the State’s argument that the statutes merely supplemented the federal scheme.  In deciding whether a state regulation should be preempted, “[t]he purpose of Congress is the ultimate touchstone.”  Congress, by allowing States to adopt their own schemes through the approval process, demonstrated its intent “to subject employers and employees to only one set of regulations.”  Thus, Illinois could either adopt OSH wholesale or submit a state plan to replace it entirely.  Limiting States to either the federal scheme or a federally approved state scheme ensured that those seeking to comply with the regulation would not need to navigate “duplicative, and possibly counterproductive, regulation[s].”  Moreover, just because Illinois also sought to promote occupational safety did not mean that its statutes were consistent with the federal scheme.  The only method for a State to enact worker’s safety laws under OSH was to first receive federal approval.  By avoiding this requirement, the Illinois statutes conflicted with (and were thus preempted by)  the Act.