Thank You For Submiting Feedback!
Supreme Court of the United States
March 19, 1984, Argued ; February 19, 1985, Decided 1
[*530] [***1020] [**1006] 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 [**1007] 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 [****5] 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. 3
[*531] Our [***1021] 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 state regulatory immunity in terms of "traditional governmental function" 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. ] That case, accordingly, is overruled.
The history of public transportation in San Antonio, Tex., is characteristic of the history of local mass transit in the United States generally. Passenger transportation for hire within San Antonio originally was provided on a private basis by a local transportation company. In 1913, the Texas Legislature authorized the State's municipalities to regulate vehicles providing carriage for hire. 1913 Tex. Gen. Laws, ch. 147, § 4, para. 12, now codified, as amended, as Tex. Rev. Civ. Stat. Ann., Art. 1175, §§ 20 and 21 (Vernon 1963). Two years later, San Antonio enacted an ordinance setting forth franchising, insurance, and safety requirements for passenger vehicles operated for hire. The city [****7] continued to rely on such publicly regulated private mass transit until 1959, when it purchased the privately owned San Antonio Transit Company and replaced it with a public authority known as the San Antonio Transit System (SATS). SATS operated until 1978, when the city transferred its facilities and equipment to appellee San Antonio Metropolitan Transit Authority (SAMTA), a public mass-transit authority organized on a countywide basis. See generally Tex. Rev. Civ. Stat. Ann., Art. 1118x (Vernon Supp. 1984). SAMTA currently is the major provider of transportation in the San Antonio metropolitan area; between 1978 and 1980 alone, its vehicles traveled over 26 million route miles and carried over 63 million passengers.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
469 U.S. 528 *; 105 S. Ct. 1005 **; 83 L. Ed. 2d 1016 ***; 1985 U.S. LEXIS 48 ****; 53 U.S.L.W. 4135; 102 Lab. Cas. (CCH) P34,633; 36 Empl. Prac. Dec. (CCH) P34,995; 27 Wage & Hour Cas. (BNA) 65
GARCIA v. SAN ANTONIO METROPOLITAN TRANSIT AUTHORITY ET AL.
Subsequent History: [****1] Reargued October 1, 1984
Petition For Rehearing Denied April 15, 1985.
Prior History: APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS.
Disposition: 557 F.Supp. 445, reversed and remanded.
sovereignty, governmental function, powers, cases, regulation, immunity, federal system, employees, functions, mass-transit, commercial power, interstate commerce, limits, overtime, delegated, national government, federal regulation, exemption, state immunity, transportation, courts, joined, state and local government, political process, state government, mass transit, principles, municipal, federal interest, Convention
Constitutional Law, Relations Among Governments, General Overview, Governments, State & Territorial Governments, Boundaries, Congressional Duties & Powers, Commerce Clause, Transportation Law, Commercial Vehicles, Traffic Regulation, Interstate Commerce, Federal Powers, Business & Corporate Compliance, Transportation Law, State Powers, Reserved Powers, Federal Government, Claims By & Against, Torts, Public Entity Liability, Immunities, Judicial Immunity, Civil Procedure, Trials, Jury Trials, Province of Court & Jury, The Judiciary, Congressional Limits, Supremacy Clause, Bill of Rights, Fundamental Rights, Equal Protection, Nature & Scope of Protection, Privileges & Immunities