Garcia v. San Antonio Metropolitan Transit Authority
| Garcia v. San Antonio Metropolitan Transit Authority | |
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| Argued March 19, 1984 Reargued October 1, 1984 Decided February 19, 1985 |
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| Full case name | Garcia v. San Antonio Metropolitan Transit Authority, et al. |
| Citations | 469 U.S. 528 (more)
105 S. Ct. 1005; 83 L. Ed. 2d 1016; 85 U.S. LEXIS 48; 53 U.S.L.W. 4135; 102 Lab. Cas. (CCH) P34,633; 36 Empl. Prac. Dec. (CCH) P34,995; 27 Wage & Hour Cas. (BNA) 65
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| Prior history | Summary judgment granted to plaintiff San Antonio Metropolitan Transit Authority, 557 F.Supp. 445 (W.D. Tex. 1982); probable jurisdiction noted, 464 U.S. 812 (1983) |
| Subsequent history | Petition for rehearing denied April 15, 1985 |
| Holding | |
| Congress had the authority under the Commerce Clause of the United States Constitution to apply the Fair Labor Standards Act to a municipal mass transit system operated by a governmental entity. District Court for the Western District of Texas reversed. | |
| Court membership | |
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| Case opinions | |
| Majority | Blackmun, joined by Brennan, White, Marshall, Stevens |
| Dissent | Powell, joined by Burger, Rehnquist, O'Connor |
| Dissent | Rehnquist |
| Dissent | O'Connor, joined by Rehnquist, Powell |
| Laws applied | |
| U.S. Const. Art. I § 8, Fair Labor Standards Act | |
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This case overturned a previous ruling or rulings
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| National League of Cities v. Usery, 426 U.S. 833 (1976) | |
Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985), is a United States Supreme Court decision in which the Court held that the Congress has the power under the Commerce Clause of the Constitution to extend the Fair Labor Standards Act, which requires that employers provide minimum wage and overtime pay to their employees, to state and local governments. In this case, the Court overruled its previous decision in National League of Cities v. Usery, 426 U.S. 833 (1976), in which the Court had held that regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution.
When Congress passed the Fair Labor Standards Act (FLSA) in 1938, it did not apply either to employees of private transit companies or to employees of state and local governments. Congress extended coverage of the FLSA's minimum wage provisions to employees of private transit companies of a certain size in 1961, then amended the Act to cover some employees of state and local governments in 1966 by withdrawing the minimum wage and overtime exemptions for public hospitals, schools, and mass transit carriers whose rates and services were subject to state regulation. At the same time, Congress eliminated the overtime exemption for all mass transit employees other than drivers, operators, and conductors. Congress later phased out these overtime exemptions when amending the Act in 1974.
The Supreme Court held in Maryland v. Wirtz, 392 U.S. 183 (1968) that Congress had the authority under the Commerce Clause to extend the FLSA to cover employees of public schools and hospitals. In 1976, however, the Court held in National League of Cities that Congress lacked authority to regulate the wages and hours of governmental employees performing "traditional governmental functions." The San Antonio Metropolitan Transit Authority (SAMTA, now known as VIA Metropolitan Transit), which had been observing the overtime requirements of federal law up to that point, responded by informing employees that it was no longer obliged to provide them with overtime pay.
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