Thursday, November 14, 2013

National League of Cities v. Usery case brief

National League of Cities v. Usery case brief summary
426 U.S. 833 (1976)

CASE SYNOPSIS
Appellants, cities and states, challenged a decision of the United States District Court for the District of Columbia, which dismissed their complaint for declaratory and injunctive relief against amendments to the Fair Labor Standards Act, 29 U.S.C.S. § 203. Appellants contended that the amendments, which eliminated their exemption from minimum wage and maximum hour requirements, intruded upon their performance of government functions.

CASE FACTS
Appellants, various cities and states, commenced an action against appellee U.S. Secretary of Labor, seeking declaratory and injunctive relief against amendments to the Fair Labor Standards Act, 29 U.S.C.S. § 203, on the ground that they were violative of the Commerce Clause of U.S. Constitutional Article I. Appellants maintained that the amendments, which eliminated a prior exemption from minimum wage and maximum hour requirements for public employees, intruded upon appellants' performance of essential government functions. Appellants challenged a district court decision dismissing the complaint for failure to state a claim.


DISCUSSION

  • The Court reversed. Congress could not exercise its power under the Commerce Clause to force its choices upon the states as to how essential decisions regarding the conduct of integral governmental functions were to be made. 
  • The amendments were unconstitutional, since apart from the substantial costs imposed upon appellants, the amendments displaced state policies regarding the manner in which they would structure delivery of governmental services which their citizens required.

CONCLUSION
The Court reversed because the amendments were violative of the Commerce Clause. The Court ruled that Congress could not force its choices upon the states as to how essential decisions regarding the conduct of integral governmental functions were to be made.

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