Garcia v. San Antonio Metropolitan Transit Authority

469 U.S. 528 (1985)


The San Antonio Metropolitan Transit Authority (D) provided mass transit transportation for the San Antonio metropolitan area. The Department of Labor ruled that D violated minimum wage and overtime requirements of the Fair Labor Standards Act (FLSA). D claimed that it was immune from these requirements since its activities were traditional government functions. D relied on the case of National League of Cities v. Usery. Garcia (P) sued for overtime pay, following the FLSA. On November 17, 1981, the District Court granted SAMTA's motion for summary judgment and denied the Secretary's and Garcia's cross-motion for partial summary judgment. Without further explanation, the District Court ruled that local public mass transit systems (including [SAMTA]) constitute integral operations in areas of traditional governmental functions under National League of Cities. The Secretary and Garcia both appealed directly to this Court pursuant to 28 U.S.C. § 1252. During the pendency of those appeals, Transportation Union v. Long Island R. Co., 455 U.S. 678 (1982), was decided. In that case, the Court ruled that commuter rail service provided by the state-owned Long Island Rail Road did not constitute a 'traditional governmental function,' and hence did not enjoy constitutional immunity, under National League of Cities, from the requirements of the Railway Labor Act. Thereafter, it vacated the District Court's judgment in the present cases and remanded them for further consideration in the light of Long Island. On remand, the District Court adhered to its original view and again entered judgment for SAMTA. P appealed.