Tuesday, November 5, 2013

Garcia v. San Antonio Metropolitan Transit Authority case brief

Garcia v. San Antonio Metropolitan Transit Authority case brief summary
469 U.S. 528 (1985)

CASE SYNOPSIS
Appellees sought review of an adverse judgment by the United States District Court for the Western District of Texas in appellees' declaratory judgment action to determine their entitlement to U.S. Constitutional Amendment X immunity from the minimum wage and overtime provisions of the Fair Labor Standards Act, 52 Stat. 1060, 1067 (1938).

CASE FACTS
Appellee, a public mass transit authority that received substantial federal funding, brought action for declaratory judgment to determine whether it was entitled to U.S. Constitutional Amendment Ximmunity from the minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA), 52 Stat. 1060, 1067 (1938). The lower court held that municipal ownership and operation of the transit system was a traditional governmental function and immune from wage and overtime standards. On appeal, appellant solicitor general argued that the court erred in extending immunity to appellee.

DISCUSSION

  • On appeal, the Court held that it was not immune from the minimum wage and overtime standards. The Court overturned the previous determination that the Commerce Clause does not empower 
  • Congress to enforce minimum-wage and overtime provisions of the FLSA because the provisions of FLSA did not destroy state sovereign immunity or violate any constitutional provision. The court reversed and remanded.

CONCLUSION
Where the Fair Labor Standards Act inappropriately extended immunity to entities engaged in traditional government functions, the Court overruled the grant of immunity and held that appellee was subject to wage and overtime standards; the decision of the lower court was reversed and the matter remanded.



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