Garcia v. San Antonio Metropolitan Transit Authority
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''Garcia v. San Antonio Metropolitan Transit Authority'', 469 U.S. 528 (1985), is a
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United States 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 ...
decision in which the Court held that the
Congress A congress is a formal meeting of the representatives of different countries, constituent states, organizations, trade unions, political parties, or other groups. The term originated in Late Middle English to denote an encounter (meeting of a ...
has the power 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 ...
of the
Constitution A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of Legal entity, entity and commonly determine how that entity is to be governed. When ...
to extend 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 ...
, which requires that employers provide
minimum wage A minimum wage is the lowest remuneration that employers can legally pay their employees—the price floor below which employees may not sell their labor. Most countries had introduced minimum wage legislation by the end of the 20th century. Bec ...
and overtime pay to their employees, to state and local governments. In this case, the Court overruled its previous decision in '' National League of Cities v. Usery'',. in which the Court had held that 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 Tenth Amendment (Amendment X) to the United States Constitution, a part of the Bill of Rights, was ratified on December 15, 1791. It expresses the principle of federalism, also known as states' rights, by stating that the federal governmen ...
.


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'' 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 ("Cradle of Freedom") , image_map = , mapsize = 220px , map_caption = Interactive map of San Antonio , subdivision_type = Country , subdivision_name = United States , subdivision_type1= U.S. state, State , subdivision_name1 = Texas , s ...
Metropolitan Transit Authority (SAMTA, now known as
VIA Metropolitan Transit VIA Metropolitan Transit (or VIA) is the mass transit agency serving San Antonio, Texas, United States, and its surrounding municipalities. It began operation in 1978 as a successor to the San Antonio Transit System. In , the system had a riders ...
), 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 The United States Department of Labor (DOL) is one of the executive departments of the U.S. federal government. It is responsible for the administration of federal laws governing occupational safety and health, wage and hour standards, unemploym ...
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 The United States District Court for the Western District of Texas (in case citations, W.D. Tex.) 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 juri ...
seeking a
declaratory judgment A declaratory judgment, also called a declaration, is the legal determination of a court that resolves legal uncertainty for the litigants. It is a form of legally binding preventive by which a party involved in an actual or possible legal mat ...
that its transit operations were beyond Congress' power to regulate. The Department of Labor 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. Usery''. 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.'', 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 Potter Stewart (January 23, 1915 – December 7, 1985) was an American lawyer and judge who served as an Associate Justice of the United States Supreme Court from 1958 to 1981. During his tenure, he made major contributions to, among other areas, ...
's famous definition of
pornography Pornography (often shortened to porn or porno) is the portrayal of sexual subject matter for the exclusive purpose of sexual arousal. Primarily intended for adults,
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.


Supreme Court


Argument and reargument

The case was argued on March 19, 1984, with
William Thaddeus Coleman, Jr. William Thaddeus Coleman Jr. (July 7, 1920 – March 31, 2017) was an American attorney and judge. Coleman was the fourth United States Secretary of Transportation, from March 7, 1975, to January 20, 1977, and the second African American to ser ...
appearing to argue for the Transit Authority and Assistant Attorney General
Theodore Olson Theodore Bevry Olson (born September 11, 1940) is an American lawyer, practicing at the Washington, D.C., office of Gibson, Dunn & Crutcher. Olson served as United States Assistant Attorney General of the Office of Legal Counsel (1981–1984) ...
arguing for the workers.Chicago-Kent College of Law at Illinois Tech. "Garcia v. San Antonio Metro. Transit Authority."
Oyez.
At the March 21 conference five Justices, including 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 ...
, voted to affirm, upholding ''National League of Cities''. Justice Blackmun had joined the Court in ''National League of Cities'' but wrote in concurrence that he was “not untroubled” by 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 ...
's majority opinion. Chief Justice
Warren E. Burger Warren Earl Burger (September 17, 1907 – June 25, 1995) was an American attorney and jurist who served as the 15th chief justice of the United States from 1969 to 1986. Born in Saint Paul, Minnesota, Burger graduated from the William Mitchell ...
preferred to assign opinions to the "least persuaded" justice, so now he asked Blackmun to write for the Court. Justice Blackmun's
law clerk A law clerk or a judicial clerk is a person, generally someone who provides direct counsel and assistance to a lawyer or judge by researching issues and drafting legal opinions for cases before the court. Judicial clerks often play significant ...
, however, convinced Blackmun that he could not write a workable opinion upholding ''National League of Cities''. On June 11 Justice Blackmun circulated a memo announcing that he was switching his vote. The case was scheduled for reargument and the Court asked for briefs on the additional question as to if ''National League of Cities'' “should be reconsidered”. At reargument on October 1 former Secretary Coleman reappeared for the Transit Authority but this time the Solicitor General of the United States
Rex E. Lee Rex Edwin Lee (February 27, 1935 – March 11, 1996) was an American lawyer and academic who served as the 37th Solicitor General of the United States from 1981 until 1985. He was responsible for bringing the solicitor general's office to the cent ...
appeared, arguing to reverse. Half of the States filed amici briefs urging affirmance, including then-Attorneys General
Joe Lieberman Joseph Isadore Lieberman (; born February 24, 1942) is an American politician, lobbyist, and attorney who served as a United States Senate, United States senator from Connecticut from 1989 to 2013. A former member of the Democratic Party (Uni ...
and
John Ashcroft John David Ashcroft (born May 9, 1942) is an American lawyer, lobbyist and former politician who served as the 79th U.S. Attorney General in the George W. Bush administration from 2001 to 2005. A former U.S. Senator from Missouri and the 50th ...
. 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.


Opinion of the Court

Writing for the majority,
Justice 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 ...
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 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 Industrial relations or employment relations is the multidisciplinary academic field that studies the employment relationship; that is, the complex interrelations between employers and employees, labor/trade unions, employer organizations, a ...
. 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 The Supremacy Clause of the Constitution of the United States ( Article VI, Clause 2) establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thu ...
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 The Seventeenth Amendment (Amendment XVII) to the United States Constitution established the direct election of United States senators in each state. The amendment supersedes Article I, Section 3, Clauses 1 and2 of the Constitution, under wh ...
. 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 Powell Lewis Franklin Powell Jr. (September 19, 1907 – August 25, 1998) was an American lawyer and jurist who served as an Associate Justice of the Supreme Court of the United States from 1972 to 1987. Born in Suffolk, Virginia, he gradua ...
, joined by
Chief Justice Burger Warren Earl Burger (September 17, 1907 – June 25, 1995) was an American attorney and jurist who served as the 15th chief justice of the United States from 1969 to 1986. Born in Saint Paul, Minnesota, Burger graduated from the St. Paul Colleg ...
,
Justice 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 1 ...
and Justice O'Connor objected to both the Court's failure to grant ''
stare decisis A precedent is a principle or rule established in a previous legal case that is either binding on or persuasive for a court or other tribunal when deciding subsequent cases with similar issues or facts. Common-law legal systems place great valu ...
'' 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 The Tenth Amendment (Amendment X) to the United States Constitution, a part of the Bill of Rights, was ratified on December 15, 1791. It expresses the principle of federalism, also known as states' rights, by stating that the federal governmen ...
, 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 vis à vis 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. Alfonso D. Lopez, Jr.'', 514 U.S. 549 (1995), was a landmark case of the United States Supreme Court concerning the Commerce Clause. It was the first case since 1937 in which the Court held that Congress had exceeded its power ...
''. 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.


See also

* List of United States Supreme Court cases, volume 469


References


External links

* {{USArticleI United States Constitution Article One case law United States Supreme Court cases United States Supreme Court cases of the Burger Court United States Supreme Court decisions that overrule a prior Supreme Court decision United States Commerce Clause case law United States public employment case law United States Tenth Amendment case law Minimum wage law 1985 in United States case law Transportation in San Antonio Railway litigation in 1985