Garcia v. San Antonio Metropolitan Transit Authority


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Significance: Using the commerce clause, the Supreme Court removed almost all limitations on Congress's power to regulate the states.

In Garcia, the Supreme Court had to determine whether the hour and wage provisions of the Fair Labor Standards Act (1938) applied to a public transportation system owned and operated by the city of San Antonio. The Court's ruling in National League of Cities v. Usery (1976) established four tests that Congress had to meet before it could regulate states under the commerce clause. These tests were unclear, and nearly ten years later they remained unclear, although the Court had made numerous rulings. By a 5-4 vote, the Court reversed Usery and removed almost all limitations on congressional power to regulate the states. Justice Harry A. Blackmun, in the opinion for the Court, opted to abandon the four tests and Usery. He argued that the states had representatives in Congress and that these members could be counted on to defend the states’ interests, pointing out the special protection states received in the Senate where every state has two senators no matter how small. This controversial decision was accompanied by a number of dissents expressing the hope that Garcia would be overturned. Lewis F. Powell, Jr., asserted that representation in Congress is an inadequate defense for the states because members of Congress, though elected from the states, become members of the federal government when they enter Congress.