Garcia v. San Antonio Metropolitan Transit Authority

In considering Garcia v. San Antonio Metropolitan Transit Authority, the Supreme Court weighed the viability of the decision first reached in National League of Cities. In that case the Court outlined four questions regarding Tenth Amendment and states' rights that should be answered before enforcing wage requirements. These questions addressed violations of state interests and sovereignty. Equally important, according to National League of Cities, was whether the service provided could be considered a "traditional governmental function." The Supreme Court threw out this qualification, arguing that any definition of a "traditional governmental function" would be arbitrary and static. Indeed, the framers of the Constitution could not have anticipated many functions performed by state governments in the modern age. The operation of a municipal airport was one example given by the Court. In overturning the National League of Cities Justice Blackmun wrote in the majority opinion that any:

attempt to draw the boundaries of state regulatory immunity in terms of "traditional governmental function" is not only unworkable but is also inconsistent with established principles of federalism.

In essence, the Court refused to judge what could be considered a state's domain in regard to commerce when delivering a public service. The Court acknowledged the volatility of state's rights in light of this decision. Justifying this opinion, the Court explained that there are limits to federal encroachment outlined in the Constitution and they should be sufficient in protecting a state's sovereignty. In this case, the majority concluded, state autonomy is not threatened by the federal overtime requirements and must be honored by SAMTA.