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[1] 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.

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.

The Supreme Court held in Maryland v. Wirtz[4] that Congress had the authority under the Commerce Clause to extend the FLSA to cover employees of public schools and hospitals.

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.

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.

[10] 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 appeared, arguing to reverse.

[7] Half of the States filed amici briefs urging affirmance, including then-Attorneys General Joe Lieberman and John Ashcroft.

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.

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.

[citation needed] Garcia represents in many ways the high-water mark[citation needed] 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.