Facts
- Congress amended the Fair Labor Standards Act (FLSA) in 1974 to extend federal minimum-wage and maximum-hours requirements to most employees of states and their political subdivisions.
- The amendments covered employees working in areas commonly administered by state and local governments, including hospitals, schools, and mass transit.
- The National League of Cities, several states, and municipalities sued the Secretary of Labor seeking declaratory and injunctive relief.
- Plaintiffs alleged the amendments, as applied to state and local governmental employers, exceeded Congress’s Commerce Clause power and violated the Tenth Amendment.
- A three-judge federal district court dismissed the complaint for failure to state a claim.
- The Supreme Court noted probable jurisdiction and reviewed the dismissal.
Issues
- Whether Congress, acting under the Commerce Clause, may impose FLSA minimum-wage and maximum-hours requirements on state and local governments as employers.
- Whether applying those requirements to “integral operations in areas of traditional governmental functions” violates the Tenth Amendment’s protection of state sovereignty.
Decision
- The Court reversed and remanded.
- By a 5–4 vote, the Court held the 1974 FLSA amendments were unconstitutional as applied to state and municipal employees engaged in traditional governmental functions.
- The Court concluded the amendments directly displaced states’ authority to structure employer–employee relationships in core governmental operations.
- The Court overruled Maryland v. Wirtz to the extent inconsistent with this holding.
- Justice Blackmun concurred in the judgment, emphasizing the line limiting federal regulation was not precisely defined and could differ where the federal interest is greater.
- Dissents argued the Tenth Amendment does not create judicially enforceable immunity from otherwise valid Commerce Clause regulation and that state interests are protected through the political process.
Legal Principles
- Congress’s Commerce Clause power, though broad, is limited when federal regulation directly restructures states’ performance of integral governmental operations.
- Federal wage-and-hour regulation is invalid when it forces states, in their sovereign capacity, to conform their employment relationships in areas of traditional governmental functions to federal choices.
- The Tenth Amendment operates as an affirmative constraint preventing federal action that impairs states’ integrity or their ability to function within the federal system.
- Judicially enforceable limits may apply when federal regulation targets states as states, rather than regulating private actors or state activities outside core governmental functions.
Conclusion
The Court held that applying the FLSA’s minimum-wage and maximum-hours requirements to state and local employees performing traditional governmental functions exceeded Congress’s Commerce Clause authority and violated the Tenth Amendment, requiring reversal of the dismissal and remand.