Garcia v. San Antonio Metropolitan Transit Authority


Under federal legislation, defendant was forced to pay plaintiff a particular amount for overtime wages.  Shortly thereafter a Supreme Court ruling stated that such legislation did not apply to employees who perform traditional government functions. on the basis that a transit system is an inherently local function and therefore was not applicable to defendant.   As such, plaintiff was denied his overtime payment rate. The defendant was told by the federal government that mass transit was not a traditional government function and therefore the Supreme Court ruling did not apply to mass transit employees.  Defendants then sued the federal government based on a theory of Congressional overreach per the interstate commerce clause.  DC held for defendants because it found mass transit was a basic function of a municipality, thereby immunizing state run transit systems.


Whether Congress can regulate wages of employees of mass transit, state-run programs.


Yes.  The court revisited their prior ruling and found that the test relating to a “traditional government function” was analytically improper.  Maintaining such a standard, the court held, would leave the decision of “traditional government function” up to bureaucrats, which is bad policy and practically unworkable.  The court held that the federal government does have the power to regulate state employee relations with their state employees; and such regulation is not a violation of constitutional federalist principles.  The court ruled that even state regulations or state-run programs can interfere with interstate commerce and consequently can be regulated by Congress.  There is no implicit limitation on Congress’s power to avoid regulating state government activity; the Supremacy Clause applies, therefore.

Leave a Reply