Summary of Garcia(Sec. Labor or Emplee) v. San Antonio Metro Transit Authority(PL)
S. Ct. 1985
Facts: Appellee San Antonio Metropolitan Transit Authority (SAMTA) is a public mass- transit authority that is the major provider of transportation in the San Antonio, Tex., metropolitan area. It has received substantial federal financial assistance under the Urban Mass Transportation Act of 1964. In 1979, the Wage and Hour Administration of the Department of Labor issued an opinion that SAMTA’s operations are not immune from the minimum-wage and overtime requirements of the Fair Labor Standards Act (FLSA) in which it was held that the Commerce Clause does not empower Congress to enforce such requirements against the States “in areas of traditional governmental functions.”SAMTA stopped overtime pay b/c of Wirtz S. Ct. decision.
Issue: Whether the State’s sovereignty is destroyed by the application of the hour and wage requirements of the FLSA, as applied to SAMTA or if FLSA is violative of the 10th Amendment?
Holding: SAMTA faces no greater obligation than 100’s of other employers. The transit authority is not immune from minimum wage and overtime requirements of the Act.
Procedure: Metropolitan transit authority brought action seeking declaratory judgment that it was entitled to Tenth Amendment immunity from minimum wage and overtime pay provisions of the Fair Labor Standards Act. On remand from the Supreme Court, the United States District Court for the Western District of Texas, entered summary judgment for transit authority, and the Secretary of Labor and intervening transit authority employee appealed. Reversed and remanded.
Rule: State sovereign interests are protected by procedural safeguards within the structure of the federal system, rather than judicially created limitations.
Ct. Rationale: Local public transit authority was not immune from minimum wage and overtime requirements of the Fair Labor Standards Act because there was nothing in those requirements that was destructive of state sovereignty or violative of any constitutional provision. A1, S8,C3; f The attempt to draw the boundaries of state regulatory immunity in terms of “traditional governmental functions” is not only unworkable but is also inconsistent with established principles of federalism and, indeed, with those very federalism principles on which National League of Cities purported to rest. That case, accordingly, is overruled. There is nothing in the overtime and minimum-wage requirements of the FLSA, as applied to SAMTA, that is destructive of state sovereignty or violative of any constitutional provision. The States’ continued role in the federal system is primarily guaranteed not by any externally imposed limits on the commerce power, but by the structure of the Federal Government itself.
PL A(SAMTA): The ownership and operation of the mass transit system is a traditional governmental function and is exempt from FLSA obligations.
Def A(Sec Labor or Employee): The FLSA and its obligations, by way of the Commerce Clause, protects the States as States. No provision limits the State’s sovereignty or constitutional power of the States.