Garcia v. San Antonio Metropolitan Transit Authority
469 U.S. 528 (1985)

  • The San Antonio Metropolitan Transit Authority (SAMTA), claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act (FLSA).
    • SAMTA argued that it was providing a traditional governmental function, which exempted it from Federal controls according to the doctrine of federalism established in National League of Cities v. Usery (426 U.S. 833 (1976)).
      • Usery had held that such regulation of the activities of State and local governments in areas of traditional governmental functions would violate the 10th Amendment.
    • SAMTA also argued that the money that the States have in their treasury would be significantly drained by if they had to pay people minimum wage. That effects the general population with regards to higher taxes, less public funding for services and infrastructure, etc.
  • Garcia, an employee of SAMTA, sued for overtime pay under the FLSA.
  • The Trial Court found for SAMTA. Garcia appealed to the US Supreme Court.
  • The US Supreme Court remanded the case back to the Trial Court for reconsideration based on their ruling in United Transportation Union v. Long Island R. Co. (455 U.S. 678 (1982)).
    • In United Transportation Union the Court had held that some transit operations were not a traditional function of government, and therefore not covered by the 10th Amendment.
  • The Trial Court once again found for SAMTA. Garcia again appealed to the US Supreme Court.
  • The US Supreme Court found for Garcia.
    • The US Supreme Court found that Congress had the power to regulate SAMTA under the Interstate Commerce Clause.
    • The Court found that the principles of federalism they established in Usery were unworkable because they was too subjective.
      • The Court found that rules based on the subjective determination of integral or traditional governmental functions provided little or no guidance in determining the boundaries of Federal and State power.
        • What makes a government function ‘traditional’? There are no hard rules.
    • The Court found that the structure of the Federal system itself, rather than any discrete limitations on Federal authority, protected State sovereignty.
  • This case represents in many ways the high-water mark for the Court’s expansive reading of the Interstate Commerce Clause to favor centralized national government as opposed to the more decentralized version of federalism, in which the 10th Amendment limits the authority of the Federal government.