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Constitutional Law Keyed to Stone
Garcia v. San Antonio Metropolitan Transit Authority
Citation:
469 U.S. 528 (1985)Facts
San Antonio Metropolitan Transit Authority (SAMTA) was a public mass-transit authority that operated in the San Antonio metropolitan area. It had evolved from a privately owned transit company that was purchased by the city in 1959 and eventually reorganized as SAMTA in 1978. SAMTA received substantial federal funding through the Urban Mass Transportation Act, with federal subsidies and local sales taxes accounting for about 75% of its operating expenses. When the Fair Labor Standards Act was extended to cover virtually all state and local government employees in 1974, SAMTA initially complied with its overtime requirements. However, after the Supreme Court’s 1976 decision in National League of Cities v. Usery, which held that the FLSA could not be constitutionally applied to the “traditional governmental functions” of state and local governments, SAMTA informed its employees that it was no longer bound by FLSA overtime provisions. In 1979, the Department of Labor issued an opinion that SAMTA’s operations were not immune from FLSA, prompting SAMTA to file for a declaratory judgment. Garcia, a SAMTA employee, intervened in support of the Secretary of Labor, seeking overtime pay under FLSA.
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