1989] AMPLIFYING THE TENTH AMENDMENT 929
were not immune from the minimum wage and overtime requirements of the FLSA.128 SAMTA is a public mass-transit authority and the major provider of transportation in the San Antonio, Texas metropolitan area. It receives substantial federal financial assistance under the Urban Mass Transportation Act of 1964. The Department of Labor based its conclusion on National League of Cities v. Usery129 which held that the Commerce Clause does not empower Congress to enforce such requirements against the states "in areas of traditional government functions."130 SAMTA then filed an action in federal district court, seeking declaratory relief. Entering judgment for SAMTA, the district court determined that municipal ownership and operation of a mass-transit system is a traditional government function and thus, under National League of Cities, is exempt from obligations imposed by the FLSA.131
On appeal, the Supreme Court ruled that, in affording SAMTA employees the protection of the wage and hour provision of the FLSA, Congress did not contravene any affirmative limit on its power under the Commerce Clause.132 Furthermore, the Court found that drawing boundaries on state regulatory immunity in terms of "traditional government functions" was not only unworkable, but inconsistent with established principles of federalism and, indeed with those principles on which National League of Cities purported to rest.133
The Court additionally held that there was nothing in the overtime and minimum-wage requirements of the FLSA, as applied to SAMTA, that destroyed state sovereignty or violated any constitutional provision.134 The Court concluded that the states, through equal representation in the Senate, would retain sufficient influence over the federal political process to ensure their autonomy and sovereign interests.135 Accordingly, the Court overruled National League of Cities.136 The Court recognized, however, that the seventeenth amendment, providing for the popular election of senators, may have altered the influence that the states now have over the federal political process, but the Court did not indicate how that influence was altered.137 The opinion implied that the states' influence over their elected representatives in Congress, as suggested by Justice Brennan's dissent in National League of Cities, is now their only recourse in the federal system; an influence that is no different from that of a lobbyist.138
Three years later, the Court decided South Carolina v. Baker.139 In that case, the State of South Carolina invoked the Supreme Court's original jurisdiction
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128. Garcia, 469 U.S. at 533-34.
129. 426 U.S. 833 (1976).
130. Id, at 852. -
131. Garcia, 469 U.S. at 528.
132. Id. at 555-56.
133. Id. at 546-47.
134. Id. at554.
135. Id. at 556.
136. Id. at 557.
137. Id. at 554.
138. National League of Cities, 426 U.S. at 857 (Brennan, J., dissenting); Garcia, 469 U.S. at 552, 556.
139. 485 U.S. 505, 108 S. Ct. 1355 (1988).
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