Garcia v. San Antonio Metropolitan Transit Authority

When the federal government first designed minimum wage and overtime requirements in 1938, transportation and government employees were exempt. In 1974 Congress enacted amendments to the Federal Labor Standards Act (FLSA) which nullified those exemptions. The San Antonio Transit System, later known as the San Antonio Metropolitan Transit Authority (SAMTA), complied with the requirements until the landmark case National League of Cities v. Usery in 1976. In that decision, the Supreme Court ruled that federal attempts to define minimum wage and overtime requirements in "areas of traditional governmental functions . . . are not within the authority granted Congress by the Commerce Clause." As the primary public transportation provider in greater San Antonio, SAMTA abandoned the requirements according to National League of Cities. In 1979, the Wage and Hour Administration of the Department of Labor decided SAMTA was not performing a "traditional governmental function" and therefore was beholden to the wage requirements set forth in the FLSA Amendments of 1974. On 21 November 1979, SAMTA filed a suit against the secretary of labor claiming that it should be exempt from the requirements. On the same day, Joe G. Garcia and other SAMTA employees seeking overtime pay filed a civil action suit against SAMTA. The decision of the employees' civil action case was postponed until the Court could ascertain whether SAMTA was exempt from the federal requirements.

SAMTA's case came before the Federal District Court for the Western District of Texas. The issue before the court was whether administering a city transportation system constituted a "traditional governmental function" as stated in National League of Cities. Although that case set forth examples of "traditional government function[s]," it did not definitively categorize services that could be considered as such. As a result, there have been several cases before federal and state courts that have turned on the interpretation of a "traditional governmental function." The district court decided that SAMTA did provide a service considered a "traditional governmental function" and was thus immune from federal wage and overtime requirements. In at least three other cases dealing with the same issue, federal courts of appeals held that municipal transportation was not a "traditional governmental function." The district court case was appealed by the secretary of labor, with Joe Garcia appearing on the appellant's behalf. A decision was entered for SAMTA again; the secretary of labor and Joe Garcia entered another appeal.