National League of Cities v. Usery
Encyclopedia
National League of Cities v. Usery, 426 U.S. 833
(1976), was a case in which the Supreme Court of the United States
held that the Fair Labor Standards Act
could not constitutionally be applied to state governments. The case was overruled by Garcia v. San Antonio Metropolitan Transit Authority
, 469 U.S. 528 (1985).
The Fair Labor Standards Act (FLSA) which was upheld in United States v. Darby was later amended to remove state exemptions pertaining to employees of state institutions. The FLSA imposed on all public employers certain minimum wage standards and maximum work hours limitations that were previously restricted to only those individual businesses and private employees engaged in interstate commerce. The amended FLSA now applied equally to all state employees including those in hospitals and schools which are areas typically thought to be outside the penumbra of "interstate commerce" regulatory powers.
The U.S. Supreme Court granted certiorari and the question(s) presented asked whether the Tenth Amendment
barred Congress from exercising its commerce powers to regulate wages, hours, and benefits of State employees, when doing so is a power traditionally reserved to states.
, Justice William Rehnquist
, writing for the majority, acknowledged that Congress may exercise power over private endeavors even when doing so preempts state law so long as the means chosen are reasonably adapted to the legitimate ends. However, the Court distinguishes the case from Darby explaining that the 10th amendment declares that Congress cannot exercise its power so as to impair the states' integrity or their ability to function effectively in a federal system. Congress may have the authority to regulate individual businesses under the Commerce Clause
, but in this case they are regulating not just individuals, but the "States as States." Additionally, they recognized that while Congress may have the affirmative authority under the Commerce Clause to reach the matter, the Constitution prohibits their regulation of it. The court found that determinations of state employee wages, and compensations, as well as the hours they may work, are "functions essential to separate and independent existence" and are state plenary powers protected from Congressional infringement. To allow otherwise, the majority reasoned, would be to neglect the federal system of government embodied by the Constitution.
The majority abandoned the reasoning applied in Maryland v. Wirtz and cited the fears of unchecked power expressed by Justice Douglas
in his dissent. They also mentioned that the FLSA's requirements would force states to restructure many of their existing policies and would result in a substantial cost burden.
's interpretation of the majority view was that it advocated the courts to use a balancing approach that weighed the importance of the government’s interest with how essential the state functions are to the state’s separate and independent existence.
Blackmun was later the swing justice who switched sides and helped overturn the case, asserting that the "traditional government functions" test he had previously supported had proved "unworkable."
Justices Brennan
and Stevens
wrote separate opinions that were dissenting.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1976), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that the Fair Labor Standards Act
Fair Labor Standards Act
The Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...
could not constitutionally be applied to state governments. The case was overruled by Garcia v. San Antonio Metropolitan Transit Authority
Garcia v. San Antonio Metropolitan Transit Authority
Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 , is a United States Supreme Court decision that holds that the Congress has the power under the Commerce Clause of the Constitution to extend the Fair Labor Standards Act, which requires that employers provide minimum wage and...
, 469 U.S. 528 (1985).
Background
This case involved a dispute concerning the extent of the government’s Commerce Clause powers over the direct activities of the State.The Fair Labor Standards Act (FLSA) which was upheld in United States v. Darby was later amended to remove state exemptions pertaining to employees of state institutions. The FLSA imposed on all public employers certain minimum wage standards and maximum work hours limitations that were previously restricted to only those individual businesses and private employees engaged in interstate commerce. The amended FLSA now applied equally to all state employees including those in hospitals and schools which are areas typically thought to be outside the penumbra of "interstate commerce" regulatory powers.
The U.S. Supreme Court granted certiorari and the question(s) presented asked whether the Tenth Amendment
Tenth Amendment to the United States Constitution
The Tenth Amendment to the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791...
barred Congress from exercising its commerce powers to regulate wages, hours, and benefits of State employees, when doing so is a power traditionally reserved to states.
Rehnquist's majority opinion
Relying on language from Heart of Atlanta Motel v. United StatesHeart of Atlanta Motel v. United States
Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241 , was a landmark United States Supreme Court case holding that the U.S. Congress could use the Constitution's Commerce Clause power to force private businesses to abide by the Civil Rights Act of 1964.- Background :This important case...
, Justice William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
, writing for the majority, acknowledged that Congress may exercise power over private endeavors even when doing so preempts state law so long as the means chosen are reasonably adapted to the legitimate ends. However, the Court distinguishes the case from Darby explaining that the 10th amendment declares that Congress cannot exercise its power so as to impair the states' integrity or their ability to function effectively in a federal system. Congress may have the authority to regulate individual businesses under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
, but in this case they are regulating not just individuals, but the "States as States." Additionally, they recognized that while Congress may have the affirmative authority under the Commerce Clause to reach the matter, the Constitution prohibits their regulation of it. The court found that determinations of state employee wages, and compensations, as well as the hours they may work, are "functions essential to separate and independent existence" and are state plenary powers protected from Congressional infringement. To allow otherwise, the majority reasoned, would be to neglect the federal system of government embodied by the Constitution.
The majority abandoned the reasoning applied in Maryland v. Wirtz and cited the fears of unchecked power expressed by Justice Douglas
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
in his dissent. They also mentioned that the FLSA's requirements would force states to restructure many of their existing policies and would result in a substantial cost burden.
Blackmun's concurrence
Justice Harry BlackmunHarry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
's interpretation of the majority view was that it advocated the courts to use a balancing approach that weighed the importance of the government’s interest with how essential the state functions are to the state’s separate and independent existence.
Blackmun was later the swing justice who switched sides and helped overturn the case, asserting that the "traditional government functions" test he had previously supported had proved "unworkable."
Justices Brennan
William J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
and Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
wrote separate opinions that were dissenting.