National League of Cities v. Usery
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''National League of Cities v. Usery'', 426 U.S. 833 (1976), was a case in which the
Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
held that the
Fair Labor Standards Act The Fair Labor Standards Act of 1938 (FLSA) is a United States labor law that creates the right to a minimum wage, and "time-and-a-half" overtime pay when people work over forty hours a week. It also prohibits employment of minors in "oppres ...
could not constitutionally be applied to state governments. The decision was overruled by the U.S. Supreme Court in ''
Garcia v. San Antonio Metropolitan Transit Authority ''Garcia v. San Antonio Metropolitan Transit Authority'', 469 U.S. 528 (1985), is a landmark United States Supreme Court decision in which the Court held that the Congress has the power under the Commerce Clause of the Constitution to extend the F ...
''.


Background

This case involved a dispute concerning the extent of the U.S. federal government’s Commerce Clause power to regulate the activities of the states. The Fair Labor Standards Act (FLSA), which was upheld in ''
United States v. Darby Lumber Co. ''United States v. Darby Lumber Co.'', 312 U.S. 100 (1941), was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, holding that the U.S. Congress had the power under the Commerce Clause to regulate emplo ...
'', was later amended to remove state exemptions pertaining to employees of state institutions. The FLSA imposed on all public employers certain minimum wage standards and maximum work hours limitations. Those limitations had previously been restricted to those individual businesses and private employees engaged in interstate commerce. After the amendment, the FLSA applied equally to all state employees including those in hospitals and schools which are areas typically thought to be outside the penumbra of "interstate commerce" regulatory powers. The
U.S. Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
granted certiorari, and the question presented was whether the Tenth Amendment barred Congress from exercising its commerce powers to regulate wages, hours, and benefits of State employees, when doing so is a power traditionally reserved to states.


Rehnquist's majority opinion

Relying on language from ''
Heart of Atlanta Motel v. United States ''Heart of Atlanta Motel, Inc. v. United States'', 379 U.S. 241 (1964), was a landmark decision of the Supreme Court of the United States holding that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title ...
'', Justice
William Rehnquist William Hubbs Rehnquist ( ; October 1, 1924 – September 3, 2005) was an American attorney and jurist who served on the U.S. Supreme Court for 33 years, first as an associate justice from 1972 to 1986 and then as the 16th chief justice from ...
, writing for the majority, acknowledged that Congress may exercise power over private endeavors even when doing so preempts state law so long as the means chosen are reasonably adapted to the legitimate ends. However, the Court distinguished the case from ''Darby'', explaining that the 10th amendment declares that Congress cannot exercise its power so as to impair the states' integrity or their ability to function effectively in a federal system. Congress may have the authority to regulate individual businesses under the
Commerce Clause The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and amon ...
, but in this case they are regulating not just individuals, but the "States as States." Additionally, the Court recognized that while Congress may have the affirmative authority under the Commerce Clause to reach the matter, the Constitution prohibits Federal regulation of that matter. The Court concluded that determinations of state employee wages, and compensations, as well as the hours they may work, are "functions essential to separate and independent existence," and that those functions are state plenary powers protected from Congressional infringement. To allow otherwise, the majority reasoned, would be to neglect the federal system of government embodied by the Constitution. The majority abandoned the reasoning applied in '' Maryland v. Wirtz''. and cited the fears of unchecked power expressed by Justice
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in his dissent. The majority also mentioned that the FLSA's requirements would force states to restructure many of their existing policies, and would result in a substantial cost burden.


Blackmun's concurrence

Justice
Harry Blackmun Harry Andrew Blackmun (November 12, 1908 – March 4, 1999) was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States from 1970 to 1994. Appointed by Republican President Richard Nixon, Blac ...
's interpretation of the majority view was that it advocated the courts to use a balancing approach that weighed the importance of the government’s interest with how essential the state functions are to the state’s separate and independent existence. Blackmun was later the swing justice who switched sides and helped overturn the case, asserting that the "traditional government functions" test he had previously supported had proved "unworkable."


See also

*
List of United States Supreme Court cases, volume 426 This is a list of all the United States Supreme Court cases from volume 426 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...


References


External links

*{{caselaw source , case=''National League of Cities v. Usery'', {{ussc, 426, 833, 1976, el=no , findlaw=https://caselaw.findlaw.com/us-supreme-court/426/833.html , justia=http://supreme.justia.com/us/426/833/case.html , loc =http://cdn.loc.gov/service/ll/usrep/usrep426/usrep426833/usrep426833.pdf , oyez =https://www.oyez.org/cases/1974/74-878 1976 in United States case law Overruled United States Supreme Court decisions United States Supreme Court cases United States Supreme Court cases of the Burger Court United States public employment case law United States Tenth Amendment case law Minimum wage law