## Facts

- The San Antonio Metropolitan Transit Authority (SAMTA) was a public mass-transit authority providing transportation in the San Antonio metropolitan area and received substantial federal funding under the Urban Mass Transportation Act of 1964.
- Joe G. Garcia, a SAMTA employee, sought overtime pay under the Fair Labor Standards Act (FLSA); the Secretary of Labor brought a companion action, later consolidated.
- In 1979, the Department of Labor’s Wage and Hour Administration concluded that SAMTA was subject to the FLSA notwithstanding National League of Cities v. Usery, which had recognized limits on Congress’s Commerce Clause power when regulating states in “traditional governmental functions.”
- SAMTA sued in federal district court for declaratory relief, asserting constitutional immunity from the FLSA.
- The district court granted summary judgment for SAMTA, holding that municipal ownership and operation of mass transit was a “traditional governmental function” and therefore exempt under National League of Cities.

## Issues

1. Whether Congress, acting under the Commerce Clause, may apply the FLSA’s minimum-wage and overtime requirements to a municipally operated mass-transit authority.
2. Whether the Tenth Amendment, as applied through National League of Cities’ “traditional governmental functions” test, renders SAMTA constitutionally immune from the FLSA.

## Decision

- The Supreme Court reversed and remanded in a 5–4 decision.
- The Court held that applying the FLSA to SAMTA fell within Congress’s Commerce Clause power and violated no affirmative constitutional limitation.
- The Court expressly overruled National League of Cities v. Usery.
- The majority rejected the “traditional governmental functions” test as unworkable and inconsistent with federalism principles.
- The dissenters objected primarily on stare decisis grounds and argued that judicially enforceable limits are necessary to protect state authority, rather than relying on the federal political process alone.

## Legal Principles

- Congress may regulate state and local governmental entities under generally applicable Commerce Clause legislation, including wage-and-hour rules, absent a distinct constitutional prohibition.
- The Tenth Amendment does not supply a judicially administered immunity from Commerce Clause regulation based on whether the regulated activity is a “traditional” state function.
- Federalism protections for states are principally supplied through the structure of the federal government and state participation in the national political process, rather than through a freestanding judicial test limiting the commerce power in this context.
- National League of Cities’ “traditional governmental functions” framework was overruled due to doctrinal administrability problems and inconsistent application.

## Conclusion

The Court held that Congress could apply the FLSA’s minimum-wage and overtime requirements to a municipal transit authority under the Commerce Clause and rejected a Tenth Amendment immunity based on “traditional governmental functions,” overruling National League of Cities and shifting federalism protection toward political, rather than judicial, constraints.


Garcia v. San Antonio Metro. Transit Auth., 469 U.S. 528 (1985)