Garcia v. San Antonio Metropolitan Transit Authority Case Brief

Facts of the case

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. SAMTA argued that it was providing a traditionalgovernmental function, which exempted it from federal controls according to the doctrine of federalism established in National League of Cities v. Usery (1976). Joe G. Garcia, an employee of SAMTA, brought suit for overtime pay under Fair Labor Standards Act.

Why is the case important?

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. Thus, it was bound by the standards of the Fair Labor Standards Act (“FLSA”).

Question

What is the scope of state immunity under the Commerce Clause?

ANSWER

None. Reversed and Remanded.
The Supreme Court of the United States (Supreme Court) holds that the determination of traditional and non-traditional state functions is an inappropriate standard for determining whether Congress may enforce the FLSA against a public employer.
The Supreme Court removes the standard by overturning National League of Cities and leaving any decisions regarding Congressional control of state actions to the political process.

CONCLUSION

The Court held that SAMTA was not immune from the minimum wage and overtime standards. The Court overturned the previous determination that the Commerce Clause does not empower Congress to enforce minimum-wage and overtime provisions of the FLSA because the provisions of FLSA did not destroy state sovereign immunity or violate any constitutional provision.

  • Advocates: William T. Coleman, Jr. Argued the cause for the appellees Theodore B. Olson Argued the cause for the appellants Laurence Stephen Gold Argued the cause for the appellant Rex E. Lee Reargued the cause for appellant, Donovan, in No. 82-1951
  • Appellant: Garcia
  • Appellee: San Antonio Metro. Transit Authority
  • DECIDED BY:Burger Court
  • Location: San Antonio Metropolitan Transit Authority
Citation: 469 US 528 (1985)
ReArgued: Oct 1, 1984
Decided: Feb 19, 1985
Argued: Mar 19, 1984
Garcia v. San Antonio Metropolitan Transit Authority Case Brief