Garcia v. San Antonio Metropolitan Transit Authority
Encyclopedia
Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528
(1985), is a United States Supreme Court
decision that holds that the Congress
has the power under the Commerce Clause
of the Constitution
to extend the Fair Labor Standards Act
, which requires that employers provide minimum wage
and overtime pay to their employees, to state and local governments. The decision overruled a previous decision of the Court, National League of Cities v. Usery
, , which had held that such regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution
.
The Supreme Court held in Maryland v. Wirtz, 392 U.S. 183 (1968) that Congress had the authority under the Commerce Clause to extend the FLSA to cover employees of public schools and hospitals. In 1976, however, the Court held in National League of Cities that Congress lacked authority to regulate the wages and hours of governmental employees performing "traditional governmental functions." The San Antonio Metropolitan Transit Authority (SAMTA, the predecessor to today's VIA Metropolitan Transit
), which had been observing the overtime requirements of federal law up to that point, responded by informing employees that it was no longer obliged to provide them with overtime pay.
In 1979, the Wage and Hour Division of the United States Department of Labor
took the position that SAMTA's operations were covered by the FLSA because they were not a traditional governmental function. SAMTA then filed suit in the United States District Court for the Western District of Texas
seeking a declaratory judgment
that its transit operations were beyond Congress' power to regulate. The Department of Labor law filed a counterclaim seeking enforcement of the Act.
Joe G. Garcia and other employees of SAMTA brought their own suit in the same court seeking to recover the overtime pay they claimed they were owed. The court stayed that action but allowed Garcia to intervene as a defendant in the SAMTA declaratory judgment action against the Department of Labor.
. Both Garcia and the Department appealed directly to the Supreme Court, which vacated and remanded the decision for reconsideration in light of its intervening decision in Transportation Union v. Long Island R. Co., 455 U.S. 678 (1982), that some transit operations were not a traditional function of government.
On remand, the district court
again held for SAMTA, ruling that the historical record showed that, even though local mass transit operations had been largely privately owned in the past, they had also been heavily regulated by state and local governments, creating at least an "inference of sovereignty". Noting that the federal government had historically exempted the operations of state and local governments from federal regulation in many instances, it ruled that refusing to apply the FLSA would not run counter to a century of regulation, as was the case in the railroad industry, and that exemption of state and local governments' operations was, in fact, a supervening federal policy. Called on to draw a distinction between those governmental functions that were traditional and those that were not, the Court analogized the task to Justice Potter Stewart
's famous definition of pornography
in Jacobellis v. Ohio
, holding that it was impossible to articulate the distinction but "someone knows it when they see it". Both Garcia and the Department of Labor appealed again.
on March 19, 1984. The Court then directed that the parties file additional briefs to address whether National League of Cities interpretation of the Tenth Amendment should be reversed. The case was reargued on October 1, 1984. In its decision, issued February 19, 1985, the Court ruled by a vote of five to four that the concept of "traditional governmental functions" was analytically unsound and that Congress had the power under the Commerce Clause to apply the FLSA to employees of state and local governments.
noted that the courts had not come up with an analytically sound distinction between traditional and non-traditional governmental operations. He noted that the Court had adopted a similar distinction decades earlier in challenges to the federal government's taxation of the operations of state governments, only to reject it as well. The Court denounced any efforts to draw this distinction, whether based on the historical record or on a historical grounds, as arbitrary and likely to be suffused with the prejudices of an unelected branch of government as to which governmental functions are proper and traditional and which ones are not.
The Court also rejected the theoretical underpinnings of the National League of Cities v. Usery decision—that the Constitution's recognition of the sovereignty of the states necessarily implies limits on the power of the federal government to regulate their employment relations. In the majority's view, the constitutional grant of authority to Congress to regulate interstate commerce was not qualified by any implied limitation on the right to regulate the activities of the states when they engaged in interstate commerce; on the contrary, the Commerce Clause invalidates state regulations that interfere with commerce, while the Supremacy Clause
allows Congress to preempt state laws that conflict with federal law in this area. According to the majority, the framers believed that state sovereignty could be maintained by the peculiar structure they adopted: a Senate in which each state was given equal representation, regardless of its population, an electoral college that gave the states the power to choose electors, and the indirect election of Senators by the legislature of each state prior to the adoption of the Seventeenth Amendment to the United States Constitution
. Noting that the same Congress that extended the FLSA to cover government-run mass transit systems also provided substantial funding for those systems, the Court concluded that the structure created by the framers had indeed protected the states from overreaching by the federal government.
, joined by Chief Justice
Warren Burger, William Rehnquist
and Sandra Day O'Connor
objected to both the Court's failure to grant stare decisis
effect to its earlier decision in National League of Cities and for reducing the balancing test that the Court adopted in National League of Cities into a cruder categorical distinction between traditional and non-traditional governmental functions. Powell's opinion was even more critical of the majority's failure to recognize any limiting role of the Tenth Amendment to the United States Constitution
, accusing it of negating the Court's role in mediating between the two through judicial review of the constitutionality of Congress' intrusions into areas previously left to the states. Powell wrote "The State's role in our system of government is a matter of Constitutional law, not legislative grace."
Garcia represents in many ways the high-water mark for the Court's expansive reading of the Commerce Clause to favor centralized national government as opposed to the more decentralized version of federalism, in which the Tenth Amendment limits the authority of the federal government vís à vís the states, as envisioned by Justices Rehnquist and O'Connor. While Chief Justice Rehnquist's later opinion in United States v. Lopez
, did not purport to overturn Garcia, it reasserted the Court's power to set limits on Congress' authority to invoke the Commerce Clause to regulate in areas that have only an insignificant connection with interstate commerce.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1985), is a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that holds that the Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
has the power under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
of the Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
to extend the Fair Labor Standards Act
Fair Labor Standards Act
The Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...
, which requires that employers provide minimum wage
Minimum wage
A minimum wage is the lowest hourly, daily or monthly remuneration that employers may legally pay to workers. Equivalently, it is the lowest wage at which workers may sell their labour. Although minimum wage laws are in effect in a great many jurisdictions, there are differences of opinion about...
and overtime pay to their employees, to state and local governments. The decision overruled a previous decision of the Court, National League of Cities v. Usery
National League of Cities v. Usery
National League of Cities v. Usery, 426 U.S. 833 , was a case in which the Supreme Court of the United States held that the Fair Labor Standards Act could not constitutionally be applied to state governments. The case was overruled by Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S...
, , which had held that such regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution
Tenth Amendment to the United States Constitution
The Tenth Amendment to the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791...
.
History
When Congress passed the Fair Labor Standards Act (FLSA) in 1938, it did not apply either to employees of private transit companies or to employees of state and local governments. Congress extended coverage of the FLSA's minimum wage provisions to employees of private transit companies of a certain size in 1961, then amended the Act to cover some employees of state and local governments in 1966 by withdrawing the minimum wage and overtime exemptions for public hospitals, schools, and mass transit carriers whose rates and services were subject to state regulation. At the same time, Congress eliminated the overtime exemption for all mass transit employees other than drivers, operators, and conductors. Congress later phased out these overtime exemptions when amending the Act in 1974.The Supreme Court held in Maryland v. Wirtz, 392 U.S. 183 (1968) that Congress had the authority under the Commerce Clause to extend the FLSA to cover employees of public schools and hospitals. In 1976, however, the Court held in National League of Cities that Congress lacked authority to regulate the wages and hours of governmental employees performing "traditional governmental functions." The San Antonio Metropolitan Transit Authority (SAMTA, the predecessor to today's VIA Metropolitan Transit
VIA Metropolitan Transit
VIA Metropolitan Transit is the mass transit agency serving San Antonio, Texas. It began operation in 1978 as a successor to the San Antonio Transit System...
), which had been observing the overtime requirements of federal law up to that point, responded by informing employees that it was no longer obliged to provide them with overtime pay.
In 1979, the Wage and Hour Division of the United States Department of Labor
United States Department of Labor
The United States Department of Labor is a Cabinet department of the United States government responsible for occupational safety, wage and hour standards, unemployment insurance benefits, re-employment services, and some economic statistics. Many U.S. states also have such departments. The...
took the position that SAMTA's operations were covered by the FLSA because they were not a traditional governmental function. SAMTA then filed suit in the United States District Court for the Western District of Texas
United States District Court for the Western District of Texas
The United States District Court For the Western District Of Texas is a Federal district court. The court convenes in San Antonio with divisions in Austin, Del Rio, El Paso, Midland, Pecos, and Waco. It has jurisdiction in over 50 Trans-Pecos, Permian Basin and Hill Country counties of the U.S....
seeking a declaratory judgment
Declaratory judgment
A declaratory judgment is a judgment of a court in a civil case which declares the rights, duties, or obligations of one or more parties in a dispute. A declaratory judgment is legally binding, but it does not order any action by a party. In this way, the declaratory judgment is like an action to...
that its transit operations were beyond Congress' power to regulate. The Department of Labor law filed a counterclaim seeking enforcement of the Act.
Joe G. Garcia and other employees of SAMTA brought their own suit in the same court seeking to recover the overtime pay they claimed they were owed. The court stayed that action but allowed Garcia to intervene as a defendant in the SAMTA declaratory judgment action against the Department of Labor.
Prior rulings
The United States District Court for the Western District of Texas granted SAMTA the declaratory judgment it sought, ruling that its transit operations were a traditional governmental function and therefore exempt from regulation under National League of Cities v. UseryNational League of Cities v. Usery
National League of Cities v. Usery, 426 U.S. 833 , was a case in which the Supreme Court of the United States held that the Fair Labor Standards Act could not constitutionally be applied to state governments. The case was overruled by Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S...
. Both Garcia and the Department appealed directly to the Supreme Court, which vacated and remanded the decision for reconsideration in light of its intervening decision in Transportation Union v. Long Island R. Co., 455 U.S. 678 (1982), that some transit operations were not a traditional function of government.
On remand, the district court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
again held for SAMTA, ruling that the historical record showed that, even though local mass transit operations had been largely privately owned in the past, they had also been heavily regulated by state and local governments, creating at least an "inference of sovereignty". Noting that the federal government had historically exempted the operations of state and local governments from federal regulation in many instances, it ruled that refusing to apply the FLSA would not run counter to a century of regulation, as was the case in the railroad industry, and that exemption of state and local governments' operations was, in fact, a supervening federal policy. Called on to draw a distinction between those governmental functions that were traditional and those that were not, the Court analogized the task to Justice Potter Stewart
Potter Stewart
Potter Stewart was an Associate Justice of the United States Supreme Court. During his tenure, he made, among other areas, major contributions to criminal justice reform, civil rights, access to the courts, and Fourth Amendment jurisprudence.-Education:Stewart was born in Jackson, Michigan,...
's famous definition of pornography
Pornography
Pornography or porn is the explicit portrayal of sexual subject matter for the purposes of sexual arousal and erotic satisfaction.Pornography may use any of a variety of media, ranging from books, magazines, postcards, photos, sculpture, drawing, painting, animation, sound recording, film, video,...
in Jacobellis v. Ohio
Jacobellis v. Ohio
Jacobellis v. Ohio, , was a United States Supreme Court decision handed down in 1964 involving whether the state of Ohio could, consistent with the First Amendment, ban the showing of a French film called The Lovers which the state had deemed obscene.Nico Jacobellis, manager of the Heights Art...
, holding that it was impossible to articulate the distinction but "someone knows it when they see it". Both Garcia and the Department of Labor appealed again.
Supreme Court proceedings
The case was arguedOral argument
Oral arguments are spoken presentations to a judge or appellate court by a lawyer of the legal reasons why they should prevail. Oral argument at the appellate level accompanies written briefs, which also advance the argument of each party in the legal dispute...
on March 19, 1984. The Court then directed that the parties file additional briefs to address whether National League of Cities interpretation of the Tenth Amendment should be reversed. The case was reargued on October 1, 1984. In its decision, issued February 19, 1985, the Court ruled by a vote of five to four that the concept of "traditional governmental functions" was analytically unsound and that Congress had the power under the Commerce Clause to apply the FLSA to employees of state and local governments.
Blackmun's opinion
Writing for the majority, Justice Harry BlackmunHarry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
noted that the courts had not come up with an analytically sound distinction between traditional and non-traditional governmental operations. He noted that the Court had adopted a similar distinction decades earlier in challenges to the federal government's taxation of the operations of state governments, only to reject it as well. The Court denounced any efforts to draw this distinction, whether based on the historical record or on a historical grounds, as arbitrary and likely to be suffused with the prejudices of an unelected branch of government as to which governmental functions are proper and traditional and which ones are not.
The Court also rejected the theoretical underpinnings of the National League of Cities v. Usery decision—that the Constitution's recognition of the sovereignty of the states necessarily implies limits on the power of the federal government to regulate their employment relations. In the majority's view, the constitutional grant of authority to Congress to regulate interstate commerce was not qualified by any implied limitation on the right to regulate the activities of the states when they engaged in interstate commerce; on the contrary, the Commerce Clause invalidates state regulations that interfere with commerce, while the Supremacy Clause
Supremacy Clause
Article VI, Clause 2 of the United States Constitution, known as the Supremacy Clause, establishes the U.S. Constitution, U.S. Treaties, and Federal Statutes as "the supreme law of the land." The text decrees these to be the highest form of law in the U.S...
allows Congress to preempt state laws that conflict with federal law in this area. According to the majority, the framers believed that state sovereignty could be maintained by the peculiar structure they adopted: a Senate in which each state was given equal representation, regardless of its population, an electoral college that gave the states the power to choose electors, and the indirect election of Senators by the legislature of each state prior to the adoption of the Seventeenth Amendment to the United States Constitution
Seventeenth Amendment to the United States Constitution
The Seventeenth Amendment to the United States Constitution established direct election of United States Senators by popular vote. The amendment supersedes Article I, § 3, Clauses 1 and 2 of the Constitution, under which senators were elected by state legislatures...
. Noting that the same Congress that extended the FLSA to cover government-run mass transit systems also provided substantial funding for those systems, the Court concluded that the structure created by the framers had indeed protected the states from overreaching by the federal government.
Powell's dissent
Justice Lewis PowellLewis Franklin Powell, Jr.
Lewis Franklin Powell, Jr. was an Associate Justice of the Supreme Court of the United States. He developed a reputation as a judicial moderate, and was known as a master of compromise and consensus-building. He was also widely well regarded by contemporaries due to his personal good manners and...
, joined by Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Warren Burger, William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
and Sandra Day O'Connor
Sandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
objected to both the Court's failure to grant stare decisis
Stare decisis
Stare decisis is a legal principle by which judges are obliged to respect the precedents established by prior decisions...
effect to its earlier decision in National League of Cities and for reducing the balancing test that the Court adopted in National League of Cities into a cruder categorical distinction between traditional and non-traditional governmental functions. Powell's opinion was even more critical of the majority's failure to recognize any limiting role of the Tenth Amendment to the United States Constitution
Tenth Amendment to the United States Constitution
The Tenth Amendment to the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791...
, accusing it of negating the Court's role in mediating between the two through judicial review of the constitutionality of Congress' intrusions into areas previously left to the states. Powell wrote "The State's role in our system of government is a matter of Constitutional law, not legislative grace."
Rehnquist's dissent
Justice Rehnquist expressed reservations as to Justice Powell's description of the standard actually adopted by the Court in National League of Cities and of the alternative standard proposed by Justice O'Connor, but reiterated his support of both dissenting opinions based on their opposition to the Court's resolution of those constitutional issues in this case.O'Connor's dissent
Acknowledging that the changes in the national economy in the past two hundred years had transformed Congress' Commerce Clause power from being a marginal power that served mostly to mediate between the states by eliminating interstate tariffs and other burdens on interstate commerce into a general power that gave Congress essentially unlimited power to regulate in every area of economic life, O'Connor argued for special limitations on this power to protect the states' authority over their own employment relations. She invoked the limiting language of the most expansive interpretations of the Commerce Clause in the Court's decisions of the 1930s and 1940s to argue that the Court retained the power to decide whether a particular exercise of the Commerce Clause authority was necessary and proper to the federal purposes to be achieved. Applying that standard, she, joined by Justices Powell and Rehnquist, would find the FLSA unconstitutional as applied to employees of state and local governments.The impact of the case
When the Court confirmed Congress' power to regulate the wage and hour standards applicable to employees of state and local governments, a different, more conservative Congress than the ones that had extended the FLSA to governmental employees in the first place now confronted the complaints from local governments that the Act was too inflexible and expensive to comply with. Congress responded by amending the Act in 1985, allowing governments to offer compensatory time off rather than overtime in some circumstances, creating an exemption for volunteers and excluding certain legislative employees from coverage under the Act. The Act also erased liabilities owed to employees who would not have been covered by the Act as interpreted by the Department of Labor's regulations prior to the Court's decision.Garcia represents in many ways the high-water mark for the Court's expansive reading of the Commerce Clause to favor centralized national government as opposed to the more decentralized version of federalism, in which the Tenth Amendment limits the authority of the federal government vís à vís the states, as envisioned by Justices Rehnquist and O'Connor. While Chief Justice Rehnquist's later opinion in United States v. Lopez
United States v. Lopez
United States v. Alfonso Lopez, Jr., was the first United States Supreme Court case since the New Deal to set limits to Congress's power under the Commerce Clause of the United States Constitution.-Background:...
, did not purport to overturn Garcia, it reasserted the Court's power to set limits on Congress' authority to invoke the Commerce Clause to regulate in areas that have only an insignificant connection with interstate commerce.