During
the course of my research of the Tenth Amendment, one of the Supreme Court
cases that I continuously encountered was National
League of Cities v. Usery, so I decided to finally read up on that specific
case.
This
case involves the Fair Labor Standards Act, which ruled that certain employers
who fell within the bounds of the Act had to provide their employees with a
minimum wage along with a 1.5x overtime pay for more than 40 hours worked per
week. This seems common today, but when the case was decided, it was not.
Eventually, the set of employers covered by the Act grew to include State and
City employees. Thus, the National League of Cities got tired of this and sued in
a District Court. The District Court ruled in favor of the defendant, but
essentially stated that the Supreme Court would likely be interested in the
case.
It
turns out they were.
The Supreme
Court did decide to hear the case. It ruled in favor of the National League of
Cities. Essentially, the Court decided that even though Congress has the power
to regulate commerce, even intrastate commerce if it affects interstate
commerce enough, expanding which employers are covered under the Fair Labor
Standards Act constituted a breach of the sovereignty of the States. The Law
also hindered the States; examples were given of the Act costing employers
thousands of dollars as well as having to decrease the number of hours of
training programs (1).
While I
feel like it is a good thing that State sovereignty was upheld by this decision,
I must say that I wonder why it was such a costly burden on the States to have
to abide by the Act. If this is due to the minimum wage requirement, it seems
like the states and/or cities were not paying their employees very much.
However, other sources have suggested that restructuring to abide by the Act
was also costly, so it might not have been only the minimum wage causing the
problem (2).
I kind
of find it difficult to feel positively about this case when it essentially
cuts down minimum wage for state/city employees. Perhaps what was under review
was whether Congress could set a minimum wage for state employees across the
nation, and the decision was that the minimum wage should be set by each individual
state. However, the decision in this case was overruled by Garcia v. San
Antonio Metropolitan Transit Authority a mere nine years later; this case state
that employers, including state and local governments, should have a minimum
wage (3). Therefore, I do not believe I misunderstood the premise of the National League of Cities case.
Webpages used:
1. "National League of Cities v. Usery - 426 U.S. 833 (1976)," Case syllabus and holding, with opinion by Mr. Justice Rehnquist, hosted by justia.com. Website not dated, accessed March 3, 2014, http://supreme.justia.com/cases/federal/us/426/833/case.html
2. "National League of Cities v. Usery," Wikipedia. Website last modified January 30, 2014, accessed March 3, 2014, http://en.wikipedia.org/wiki/National_League_of_Cities_v._Usery. Referred to by Brett Kissane.
3. "Garcia v. San Antonio Metropolitan Transit Authority," Wikipedia. Website last modified January 30, 2014, accessed March 3, 2014, http://en.wikipedia.org/wiki/Garcia_v._San_Antonio_Metropolitan_Transit_Authority
I believe that you may be correct about the states not having been paying their employees enough. However, I think that may have caused more of a cost to them than you mentioned, for a change in wages that large likely resulted in the states having to alter the way people received that money, and changing well established policies and routines is never easy, and likely not cheap. Also, it makes sense that the court was reluctant to allow the federal government to control what the states were doing in regards to their own employees, though I feel the argument could be made that paying people so little resulted in them not having the money they needed to live on and buy things to stimulate the economy, so perhaps a commerce argument could be made on those points. Maybe that came up in the transit authority case that overturned it. Regardless, this was a most intriguing read.
ReplyDelete-Brett Kissane