The U.S. Const. amend. X expressly declares the constitutional policy that Congress may not exercise power in a fashion that impairs the states' integrity or their ability to function effectively in a federal system.
Appellants, various cities and states, commenced an action against appellee U.S. Secretary of Labor, seeking declaratory and injunctive relief against amendments to the Fair Labor Standards Act, 29 U.S.C.S. § 203, on the ground that they were violative of the Commerce Clause of U.S. Const. art. I. Appellants maintained that the amendments, which eliminated a prior exemption from minimum wage and maximum hour requirements for public employees, intruded upon appellants' performance of essential government functions. Appellants challenged a district court decision dismissing the complaint for failure to state a claim.
May Congress amend a law that would impair the states' integrity or their ability to function effectively in a federal system?
The Court reversed. Congress could not exercise its power under the Commerce Clause to force its choices upon the states as to how essential decisions regarding the conduct of integral governmental functions were to be made. The amendments were unconstitutional, since apart from the substantial costs imposed upon appellants, the amendments displaced state policies regarding the manner in which they would structure delivery of governmental services which their citizens required.