Garcia v. San Antonio Metropolitan Transit Authority
Garcia v. San Antonio Metropolitan Transit Authority is a significant Supreme Court case that addressed the application of the Fair Labor Standards Act (FLSA) to a public transportation system operated by the city of San Antonio. The case arose in the context of a prior ruling, National League of Cities v. Usery, which had established criteria for Congress to regulate state entities under the commerce clause. However, the standards set by Usery were found to be ambiguous, leading to ongoing legal uncertainty. In a narrow 5-4 decision, the Supreme Court reversed the Usery ruling, removing many limitations on congressional authority to oversee state operations.
Justice Harry A. Blackmun, in the opinion for the Court, contended that states are sufficiently represented in Congress, as each state has equal representation in the Senate regardless of size. This decision sparked considerable debate, with dissenting opinions expressing concern over the adequacy of congressional representation as a safeguard for state interests. Critics argued that once elected, members of Congress prioritize federal government responsibilities over state concerns. The ruling marked a pivotal moment in the relationship between state and federal powers, influencing future discussions on congressional authority and states' rights.
Garcia v. San Antonio Metropolitan Transit Authority
Date: February 19, 1985
Citation: 469 U.S. 528
Issue: Commerce clause
Significance: Using the commerce clause, the Supreme Court removed almost all limitations on Congress’s power to regulate the states.
In Garcia, the Supreme Court had to determine whether the hour and wage provisions of the Fair Labor Standards Act (1938) applied to a public transportation system owned and operated by the city of San Antonio. The Court’s ruling in National League of Cities v. Usery (1976) established four tests that Congress had to meet before it could regulate states under the commerce clause. These tests were unclear, and nearly ten years later they remained unclear, although the Court had made numerous rulings. By a 5-4 vote, the Court reversed Usery and removed almost all limitations on congressional power to regulate the states.
Justice Harry A. Blackmun, in the opinion for the Court, opted to abandon the four tests and Usery. He argued that the states had representatives in Congress and that these members could be counted on to defend the states’ interests, pointing out the special protection states received in the Senate where every state has two senators no matter how small. This controversial decision was accompanied by a number of dissents expressing the hope that Garcia would be overturned. Lewis F. Powell, Jr., asserted that representation in Congress is an inadequate defense for the states because members of Congress, though elected from the states, become members of the federal government when they enter Congress.