Case Brief of Garcia v. San Antonio Metropolitan Transit Authority (1985) PDF

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This is a case brief following the suit of Joe Garcia, an employee for the San Antonio Metropolitan Transit Authority (SAMTA), and the issue of congressional regulation and the principles of federalism....

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Jacquie Lagaza Dr. Benesch HIS 215 October 22nd, 2021 Garcia v. San Antonio Metropolitan Transit Authority (1985) The Metropolitan Transit Authority of San Antonio, or SAMTA, had claimed that they were exempt from the overtime and minimum wage pay requirements under the Fair Labor Standards Act. The FLSA was decided in the National League of Cities v. Usery case to require businesses their compliance with the legislation, which made the limit of power within the state of non-traditional or 'not found' under the FLSA protected. This became controversial to SAMTA due to 'traditional' services of transits. They also felt exempt from the federalism doctrine of 1976 decided by the National League of Cities v. Usery case, arguing that federalism had no legislation over state sovereignty, seemingly putting SAMTA under this immunity from the doctrine. With these statements of exemption, SAMTA had caused wage issues among the employees for the transit service. Hence the suit by an employee named Joe G. Garcia to file for overtime pay against SAMTA. Both Garcia and SAMTA went to the Supreme Court right away, one of the hundred or so cases out of the thousands that appealed to the Court directly. The only district court used was for SAMTA; this was for their exemption approval from the FLSA and, since it is federal level, SAMTA had to go onto the Supreme Court since Garcia went to the Court first, even with the approval of the District Court. So, the question stands as federalism, and its very foundations come into play; are the requirements of the FLSA's wages and overtime hours of transit employees immune for

Jacquie Lagaza Dr. Benesch HIS 215 October 22nd, 2021 companies like SAMTA to be exempt from, and does it put them under violation of the Tenth Amendment? With a 5-4 decision for Garcia, Justice Blackmun delivered the opinion of the Court, stating how the reference to the National League of Cities v. Usery case with 'traditional' governmental services examined under the Commerce Clause had no consistency with the principles of federalism. The methods taken to find immunity are done in four steps. This case focuses on the "Third, state compliance with the Federal obligation must "directly impair [the States'] ability 'to structure integral operations in areas of traditional governmental functions' " (O'Brien, 718). Since there is no real identification for these types of functions that the Court established prior, it has no evidence that SAMTA is immune from the wage requirements of the FLSA. This also brought in SAMTA being a factor of interstate commerce, making them under Congressional power in the Commerce Clause, contradicting their initial exemption argument. Other times Congressional power in interstate commerce activities come into Court are precedent cases like Hodel v. Virginia Surface Mining & Recl. Assn, Wickard v. Filburn, and United States v. Darby are prominent. These all presented the issue with the Commerce Clause tested between state and congressional power. Those cases guided the Court along the path to see the constitutionality of FLSA and powers under the Tenth Amendment. Those who dissented, like Chief Justice Burger and Justice Powell, felt a wrongful choice in altering the federal system of the constitution. In their opinions, "overruling National League of Cities, the Court incorrectly characterizes the mode of analysis established therein and developed in subsequent cases" (O'

Jacquie Lagaza Dr. Benesch HIS 215 October 22nd, 2021 Brien, 724). After dissents showed their opinions for the federalist system, the Court concluded that the federalism plan's structure protected state sovereignty without going against the constitution and that the Congressional had not "contravened no affirmative limit on Congress' power under the Commerce Clause" (O' Brien, 724). Although tightly divided in this decision, the Court gave no reason to violate their power under the Commerce Clause. The overturn of the National League of Cities shows that businesses need more requirements in exemption from the Fair Labor Standards Act, rather than just the claim of being a 'traditional' governmental service. The doctrine was a well-noted piece of legislation to support the identification of businesses under the FLSA. It seems that fundamentals of federalism would protect the steps Supreme Court takes to assure a company under the Fair Labor Standards Act. Considering the idea of traditionalism is argued, transportation is a type of public service that requires state and federal standards for both the service and employees. The Court seemingly recognizes the standards that employees are required, therefore turning over the National League of Cities v. Usery case. Overall, the principles of federalism lead the Courts decision well despite the strict divide.

Jacquie Lagaza Dr. Benesch HIS 215 October 22nd, 2021 References O'BRIEN, D. A. V. I. D. M. (2020). Constitutional law and politics: Struggles for power and Governmental accountability (11th ed., Vol. 1). W W NORTON....