1. Garcia v. San Antonio Metro. Transit Auth., (1985)
2. Facts: Garcia was a bus driver who worked overtime hours. Under the FLSA, the ∆, SAMTA, was required to pay a certain wage and comply with certain overtime standards. However, four months after the Supreme Court’s ruling in National League of Cities, that the FLSA did not apply to state government agencies “in areas of traditional government functions,” SAMTA notified its employees that the decision relieved it of its overtime obligations under the FLSA because a municipal public mass-transit system was traditionally a local government function, and therefore immune from FLSA.
3. Procedural Posture: Garcia sued for his overtime pay under the FLSA. The District Court found that a municipal operation of a mass transit system was a traditional government function, and thus under National League of Cities, is exempt from the FLSA wage and overtime obligations.
4. Issue: Whether Congress has the power, under the Commerce Clause, to regulate activities and functions that are “traditionally” an “integral” part of state government operations.
5. Holding: Yes. The fundamental limitation that the constitutional scheme imposes on Congress’ power under the commerce clause to protect “states as states” from intrusion by federal regulation is a procedural one to be found in the political process - states’ and citizens’ participation in federal governmental action.
6. Majority Reasoning: The test of National League of Cities [also the third prong of the test in Hodel], that Congress may not interfere with “traditional” state government functions, is unworkable. There is no meaningful way to determine what is a “traditional” or “integral” part of a state government’s function, and what is not. Such an approach has led to artificial results since its enactment. History is not a viable grounds for a determination because this prevents meaningful change when necessary, as well as being fairly arbitrary. Furthermore, it requires the unelected judiciary to review legislative decisions based on which policies it likes and dislikes. [This argument goes contrary to Marbury.] If Congress has a particular power, it does not matter whether it interferes with the laws of the states. To find limits on the commerce power, the constitution itself must be examined. Since there are no express limits, the constitution suggests that the structure of the federal government itself is the process by which it is regulated; i.e. by state representatives to the federal government. The states’ interests are best protected by their own representation in the federal government. Since the FLSA is a lesser burden on the states than many other Acts, it is evidence of the political pressures on the federal government to protect states’ rights. Thus, National League of Cities is overruled.
7. Dissent Reasoning: [Powell] reasoned that the majority rendered the 10th amendment [reservation of power to the states] meaningless. The “balancing test” of National League of Cities was best designed to protect the states while allowing the Congress proper power. The majority also failed to explain how the states’ role in the electoral process protects them in their capacity as states themselves. The fact that Congress does not generally exceed its constitutional limits to reach state activities does not make judicial review any less necessary on those occasions that it does. The States’ rights are a matter of congressional law, not legislative grace. Congress has passed increasingly more legislation of this type, while at the same time losing ground with its local constituents. This poses a danger for future stability of the federal government because it undermines the constitutional balance of power between the federal government and the states. Furthermore, it is clerks and aids who normally draft legislation, not the Senators themselves. Thus, the drafters are even one more step removed from the constituents who best know how to govern their local agencies. Since the FLSA is so economically intrusive, it clearly violates the “balance” established by National League of Cities.
8. Dissent Reasoning : [O’Connor] felt that the majority had backed down from the fight for states’ rights just when the states needed help from the Supreme Court. There is now a risk that Congress will gradually erase the diffusion of power between state and nation on which the Framers relied. Such a fear is not unwarranted given the amount of similar legislative activity in the last 30 years. The proper test should be weighing the states’ rights as a “relevant consideration” in determining the constitutionality of uses of the commerce power.
