Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528; 105 S. Ct. 1005; 83 L. Ed. 2d 1016 (1985)

Facts—The San Antonio Metropolitan Transit Authority (SAMTA) is a public mass transit authority. The Department of Labor held that SAMTA’s operations are not immune from the minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA) under National League of Cities v. Usery (1976). It was held that the commerce clause does not empower Con- gress to enforce such requirements against the states in an area of “traditional governmental function.” The District Court held that a mass transit system is a traditional governmental function and under the Usery decision is exempt from the obligations imposed by the FLSA.

Question—May Congress regulate the wages of state transit employees under its commerce power without violating the powers reserved to the states under the Tenth Amendment?

Decision—Yes.

Reasons—J. Blackmun (5–4). The attempt to draw “the boundaries of state regulatory immunity in terms of traditional governmental function” is not only unworkable, but it also collides with federalist principles. This being so, the case of National League of Cities accordingly is overruled. During the pendency of Garcia “the Court ruled that a community rail service provided by the state-owned Long Island Rail Road did not constitute a ‘traditional governmental function’ and hence did not enjoy constitutional immunity.

. . .” It long has been settled that Congress’s authority “under the Commerce Clause extends to intrastate economic activities that affect interstate Commerce.” Although the Court has difficulty drawing the line on what is or is not a governmental function—the only case to address this problem is Long Island—still “we simultaneously disavow ‘a static historical view of state functions generally immune from federal regulation.’” Any rule of state immunity that looks to the “traditional,” “integral,” or “necessary” nature of governmental functions inevitably invites an unelected federal judiciary to make decisions about which state policies it favors and which ones it dislikes. The judgment of the district court is reversed. The majority argued that state interests were adequately protected by state representation in Congress and in the electoral college

J. Powell and J. O’Connor authored vigorous dissents. Powell argued that “The States’ role in our system of government is a matter of constitutional law, not of legislative grace.” O’Connor evoked the “spirit” of the Tenth Amendment.