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 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 Fair Labor Standards Act , which requires that employers provide minimum wage 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 .

Contents

• 1 History

• 2 Prior rulings

• 3 Supreme Court

  • 3.1 Argument and reargument

  • 3.2 Opinion of the Court

  • 3.3 Powell's dissent

  • 3.4 Rehnquist's dissent

  • 3.5 O'Connor's dissent

• 4 The impact of the case

• 5 See also

• 6 References

• 7 External links

History

(https://en.wikipedia.org/w/index.php?title=Garcia_v._San_Antonio_Metropolitan_Transit_Authority&action=edit&section=1 "Edit section: 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 Metropolitan Transit Authority (SAMTA, now known as VIA Metropolitan Transit ), 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 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 seeking a declaratory judgment 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

(https://en.wikipedia.org/w/index.php?title=Garcia_v._San_Antonio_Metropolitan_Transit_Authority&action=edit&section=2 "Edit section: 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 's famous definition of pornography 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

(https://en.wikipedia.org/w/index.php?title=Garcia_v._San_Antonio_Metropolitan_Transit_Authority&action=edit&section=3 "Edit section: Supreme Court")

Argument and reargument

(https://en.wikipedia.org/w/index.php?title=Garcia_v._San_Antonio_Metropolitan_Transit_Authority&action=edit&section=4 "Edit section: Argument and reargument")

The case was argued on March 19, 1984, with William Thaddeus Coleman Jr. appearing to argue for the Transit Authority and Assistant Attorney General Theodore Olson arguing for the workers.

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