Maryland v. Wirtz - Federal Regulation Vs. States' Rights

The decision in Maryland v. Wirtz was overturned after only eight years, in a decision called National League of Cities v. Usery (1976). The majority in National League seemed to agree with the minority in Wirtz, finding that a state was not just another entity in the economy but was a special, independent element that had been given a unique place in the Constitution. Thus in National League, the Court held that when federal and state interests collided, federal interests frequently had to give way.

But this decision was overruled again in Garcia v. San Antonio Metropolitan Transit Authority (1986). In Garcia, the Court appeared to go back to its original finding in Wirtz: that with rare exceptions, the Constitution had not given any kind of sacred power to the states.

Garcia built upon Wirtz, taking that decision one step further. In Garcia, the Court held that states' power lay not in any constitutional guarantees, but in the political process itself. The people of each state could elect men and women to Congress. These representatives would presumably refrain from taking any actions that might hurt the states who had elected them. This is the definition of federalism that still stands, despite critics' fears of a federal policy that might cause economic or other hardships to the states.