However, these shifting interpretations are usually incremental and historically disparate. Reargued October 1, 1984. Citation 22 Ill.469 U.S. 528, 105 S. Ct. 1005, 83 L. Ed. SCOTUS overruled Nat'l League of Cities. Decided Feb. 19, 1985. Garcia v. San Antonio Transit Authority. Nos. Indeed, the prediction of Justice William Rehnquist in his dissent that Garcia would not hold and that the respect for state sovereignty expressed in National League would again “in time command a majority of this Court” (Garcia v. San Antonio Metropolitan Transit Authority 469 U.S. 528 [1985]) was soon to be fulfilled in the enduring federalism debate. GARCIA v. SAN ANTONIO METRO. In a 5–4 vote in Garcia, the U.S. Supreme Court overruled its decision in National League of Cities v. Usery (1976), which had said that the individual states were not subject to wage and hour protections under the Fair Labor Standards Act as applied “in … And John Kincaid accused the Court of abandoning “the field, abdicating its role as umpire of the federal system” (Kincaid 1993, 172). No. Syllabus. 82-1913 Argued: March 19, 1984 Decided: February 19, 1985 [ Footnote * ] Together with No. Thomas Anton, American Federalism and Public Policy (Philadelphia: Temple University Press, 1989); Mark R. Killenbeck, The Tenth Amendment and State Sovereignty: Constitutional History and Contemporary Issues (Lanham, MD: Rowman & Littlefield, 2002); John Kincaid, “Constitutional Federalisms Labor’s Role in Displacing Places to Benefit Persons,” P.S. TRANSIT AUTH. As such, it found National League an unworkable standard and rejected this balancing approach of determining whether an issue being regulated by Congress affected an individual state’s traditional governmental functions. Political Science and Politics 26, no. Reargued Oct. 1, 1984. The dissent in Garcia argued that despite the claim of the majority opinion that this ruling secured the concept of federalism, the reality was that the Tenth Amendment was effectively reduced to “meaningless rhetoric” as to issues involving the Commerce Clause. In other words, each state has elected U.S. senators and representatives who are expected to protect the state’s interests and rights. Issues. Procedural History. The San Antonio Metropolitan Transit Authority (SAMTA), the main provider of transportation in the San Antonio metropolitan area, claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act. Should Nat'l League of Cities be overruled? This page was last edited on 18 October 2019, at 20:11. Garcia v. San Antonio Metropolitan Transit Authority. 2 (June 1993): 172; and Tinsley E. Yarbrough, The Rehnquist Court and the Constitution (New York: Oxford University Press, 2000). Congress enacted a statue, which regulated minimum wage and overtime provisions applicable to all businesses of a certain size. Decided February 19, 1985* 469 U.S. 528. 2d 1016, 27 WH Cases 65 (1985) Brief Fact Summary. Garcia and the Department of Labor appealed directly to the United States Supreme Court. SEE ALSO: National League of Cities v. Usery; Tenth Amendment, http://encyclopedia.federalism.org/index.php?title=Garcia_v._San_Antonio_Metropolitan_Transit_Authority_(1985)&oldid=2573. Argued March 19, 1984. Justice Sandra Day O’Connor in dissent remarked that “the Court today surveys the battle scene of federalism, and sounds a retreat.” Federalism scholar Thomas Anton remarked, “Important and thoughtful as the Garcia ruling may be, we should not imagine that it signifies the end to the debate [over federalism]” (Anton 1989, 16). (1985) No. Garcia v. San Antonio MTA SCOTUS- 1985 Facts. 82-1913. The Appellant, Garcia (Appellant), brought suit against his employer the San Antonio Metropolitan Transit Authority (Appellee), arguing that its function as a transit authority was a “non-traditional” function of state government. Argued March 19, 1984. Case regarding Congressional wage regulation, through the FLSA, of state government-run mass transit. Synopsis of Rule of Law. 82-1951, Donovan, Secretary of Labor v. San Antonio Metropolitan Transit Authority et al., also on appeal from the same court. While the Tenth Amendment provides states, or the people, reserved powers not delegated to the federal government by the Constitution or prohibited by it to the states, the courts have shifted in the interpretation of this amendment over time, sometimes moving toward a strict constructionist view and protecting states’ rights and at other times taking an expansive view of federal powers. Justice Harry Blackmun wrote for the majority that these “political safeguards,” and particularly that of the states’ representation in the Senate, were sufficient constitutional safeguards of states’ rights. In Garcia v. San Antonio Metropolitan Transit Authority (1985), the Supreme Court made a strong redirection on federalism in interpreting the Tenth Amendment. Thus, it was bound by the standards of the Fair Labor Standards Act (“FLSA”). 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. Rehearing Denied April 15, 1985. The United States Supreme Court remanded the case, and the district court again ruled for SAMTA. In a 5–4 vote in Garcia, the U.S. Supreme Court overruled its decision in National League of Cities v. Usery (1976), which had said that the individual states were not subject to wage and hour protections under the Fair Labor Standards Act as applied “in areas of traditional governmental functions.” The Garcia Court, however, found that defining “traditional governmental functions” was a major task for the various courts. In replacing the balancing approach, the Garcia Court determined that individual states were protected from inappropriate federal regulations against the states by their participation in the federal political process. It was therefore presumed by the majority that the legislative process will work properly and therefore the courts will give great deference to the actions of Congress when it is a matter of regulating both states and private entities.

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