Garcia v. San Antonio Metropolitan Transit Authority
Summary
In a 5-4 decision, the Supreme Court ruled that the Commerce Clause empowers the federal government to regulate the terms of employment of state workers. This case upheld the minimum wage requirement of the Fair Labor Standards Act (FLSA), as applied to state governments. This reversed National League of Cities v. Usery (1976), in which the Court ruled that imposing a minimum wage requirement on state governments violated the Tenth Amendment.
Analysis
This opinion strains the text of the Commerce Clause to the point of breaking in order to uphold the application of federal regulation to conduct that is not interstate. In a decision by Justice Blackmun, the Court abuses precedent by reinforcing the grave errors of Wickard, reasoning that state and local government wage policies, while intrastate in nature, substantially affect interstate commerce. Thus, they can be preempted by the federal government.
Here, the damage to the Constitution is twofold: the Court both abuses the Commerce Clause and renders the Tenth Amendment a nullity. In Usery, the Court concluded that wage policy for state employees was a “traditional government function” protected by the Tenth Amendment. But under Garcia, states are at the mercy of the federal government, even when exercising powers that have traditionally been theirs.
Case Basics
date02/19/1985
Court & Reporter NumberSupreme Court, 469 U.S. 528
Type(s) of Activism
- Contorting Text
- Abusing Precedent
Area(s) of law
- Federalism
- First Amendment
Opinion(s)
Majority
- Harry A. Blackmun
- William J. Brennan
- Thurgood Marshall
- John Paul Stevens
- Byron R. Whit
Dissent
- Sandra Day O'Connor
- Lewis Franklin Powell, Jr.
- William H. Rehnquist
- Warren Earl Burger