In that 1976 case, the Supreme Court ruled that the Fair Labor Standards Act of 1938 could not be applied to state employers under the Commerce Clause because it would diminish their sovereignty.

[2] The Supreme Court held that this law passes rational basis review by recognizing Congress' six years of pre-enactment findings that "surface coal mining activities have imposed large social costs on the public [...] in many areas of the country in the form of unreclaimed lands, water pollution, erosion, floods, slope failures, loss of fish and wildlife resources, and a decline in natural beauty".

[3] While National League of Cities v. Usery would not be overruled until four years later in Garcia v. San Antonio Metropolitan Transit Authority, Marshall considered that case inapplicable to this dispute because the entities being regulated were private surface mines, rather than state governments.

[2] Associate Justice William Rehnquist concurred with Marshall's judgement, but he argued against a gradual widening of federal power under past Commerce Clause case law.

However, Powell noted that the plaintiffs would be likely to prevail in post-enforcement litigation because in most regions of Virginia suitable for surface coal mining, the land is too steep to grow crops or timber.