Garcia v. San Antonio Metropolitan Transit Authority et al. (469 U.S. 528)

U.S. Supreme Court · decided February 19, 1985 · Supreme Court Database (Spaeth)

Citation
469 U.S. 528 · 105 S. Ct. 1005
Decided
February 19, 1985
Term
October Term 1984
Vote
5–4
Majority author
Justice Blackmun
Issue area
Unions
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Liberal

Opinion excerpt

Justice Blackmun delivered the opinion of the Court. We revisit in these cases an issue raised in National League of Cities v. Usery, 426 U. S. 833 (1976). In that litigation, this Court, by a sharply divided vote, ruled that the Commerce Clause does not empower Congress to enforce the minimum-wage and overtime provisions of the Fair Labor Standards Act (FLSA) against the States “in areas of traditional governmental functions.” Id., at 852. Although National League of Cities supplied some examples of “traditional governmental functions,” it did not offer a general explanation of how a “traditional” function is to be distinguished from a “nontraditional” one. Since then, federal and state courts have struggled with the task, thus imposed, of identifying a traditional function for purposes of state immunity under the Commerce Clause. In the present cases, a Federal District Court concluded that municipal ownership and operation of a mass-transit system is a traditional governmental function and thus, under National League of Cities, is exempt from the obligations imposed by the FLSA. Faced with the identical question, three Federal Courts of Appeals and one state appellate court have reached the opposite conclusion. Our examination of this “function” standard applied in these and other cases over the last eight years now persuades us that the attempt to draw the boundaries of…

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