Garcia v. San Antonio Metropolitan Transit Authority
Citation and Court
469 U.S. 528 (1985). United States Supreme Court. Justice Blackmun, writing for the Court (5-4).
Facts
The San Antonio Metropolitan Transit Authority (SAMTA) operated a public mass transit system and claimed it was immune from the minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA) because it was a governmental entity. SAMTA relied on National League of Cities v. Usery (1976), in which the Court had held that the Commerce Clause did not permit Congress to apply FLSA to state employees performing “traditional governmental functions.” The Department of Labor brought suit, and SAMTA appealed on sovereignty grounds.
Issue
Does the Commerce Clause authorize Congress to apply the Fair Labor Standards Act’s wage and hour requirements to a state-owned mass transit authority, notwithstanding the Tenth Amendment and federalism principles recognized in National League of Cities v. Usery?
Holding
Yes. National League of Cities v. Usery is overruled. The FLSA applies to SAMTA. The Tenth Amendment does not immunize states from generally applicable federal regulations enacted under the Commerce Clause.
Rule / Doctrine
Political Process as Primary Safeguard of Federalism: The principal means by which the Constitution protects state sovereignty is through the structure of the federal government itself — in particular, state representation in the Senate and the Electoral College — not through judicially enforced limits on Commerce Clause power. Courts are institutionally incapable of drawing principled lines between “traditional” and “non-traditional” governmental functions. States must protect their interests through the political process.
Significance
Garcia is significant for what it overruled as much as what it held. By overruling National League of Cities, the Court abandoned the project of using the Tenth Amendment to shield states from generally applicable federal law. It left the political process as the primary constitutional protection for state sovereignty, a position that the Rehnquist Court subsequently reconsidered in New York v. United States (1992) and Printz v. United States (1997), which revived Tenth Amendment limits on federal power through the anti-commandeering doctrine.