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Keywords

lawsuitdeclaratory judgment

appealappellee

Related Cases

Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528, 105 S.Ct. 1005, 83 L.Ed.2d 1016, 27 Wage & Hour Cas. (BNA) 65, 36 Empl. Prac. Dec. P 34,995, 53 USLW 4135, 102 Lab.Cas. P 34,633

Facts

SAMTA is a public mass-transit authority in San Antonio, Texas, which has received significant federal funding under the Urban Mass Transportation Act of 1964. In 1979, the Department of Labor determined that SAMTA's operations were not immune from the FLSA's minimum wage and overtime requirements. SAMTA filed a lawsuit seeking a declaratory judgment to assert its claimed immunity, which the District Court initially granted, stating that municipal ownership and operation of a mass-transit system is a traditional governmental function exempt from FLSA obligations.

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.

Issue

Whether the San Antonio Metropolitan Transit Authority is entitled to Tenth Amendment immunity from the minimum wage and overtime provisions of the Fair Labor Standards Act.

Whether or not the principles of the Tenth Amendment as set forth in National League of Cities v. Usery, 426 U.S. 833 [96 S.Ct. 2465, 49 L.Ed.2d 245] (1976) should be reconsidered?

Rule

The Supreme Court ruled that the application of the FLSA to state and local government employees does not violate the Tenth Amendment, and that Congress has the authority under the Commerce Clause to enforce minimum wage and overtime provisions against state entities.

Held: In affording SAMTA employees the protection of the wage and hour provisions of the FLSA, Congress contravened no affirmative limit on its power under the Commerce Clause.

Analysis

The Court analyzed the historical context of state functions and the role of federal authority, concluding that the attempt to define state regulatory immunity based on 'traditional governmental functions' was unworkable. The Court emphasized that the FLSA's wage and hour provisions do not impair state sovereignty and that the political process effectively protects the states' role in the federal system.

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.

Conclusion

The Supreme Court reversed the District Court's ruling, holding that SAMTA is not immune from the FLSA's requirements. The case was remanded for further proceedings consistent with this opinion.

557 F.Supp. 445, reversed and remanded.

Who won?

The Secretary of Labor prevailed in the case, as the Supreme Court ruled that SAMTA was not entitled to immunity from the FLSA, thereby affirming the applicability of federal wage and hour laws to state entities.

The Secretary and Garcia both appealed directly to this Court pursuant to 28 U.S.C. § 1252.

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