In the 1984 case Garcia et al. v. United States, the U.S Supreme Court ruled that federal law could be applied to state government activities without violating the Tenth Amendment or principles of federalism. The case arose when employees of a public transit system in San Antonio, Texas sued their employer for failing to pay overtime wages as required by the Fair Labor Standards Act (FLSA). The city argued that applying FLSA provisions to states was unconstitutional under National League of Cities v. Usery precedent which protected states' rights from congressional overreach into traditional areas of state control like labor regulations. However, in a 5-4 decision led by Justice Blackmun, it overturned this precedent and held that Congress had authority under Commerce Clause to extend FLSA's minimum wage and overtime protections to state and local governments; thus rejecting any distinction between "integral" and "traditional" governmental functions as bases for constitutional immunity from federal regulation. The court reasoned that political safeguards inherent within structure of Federal Government were sufficient protection against national intrusion into state sovereignty rather than judicially created limitations on Congressional power based on subjective determinations about what constitutes 'traditional' governmental function.

In the dissenting opinion for Garcia et al. v. United States, Justice O'Connor argued that the majority's decision to allow Congress to regulate state activities under its commerce power was a departure from previous precedents and threatened states' rights. She contended that this ruling could lead to federal overreach into areas traditionally controlled by states, such as education and family law. The justice also criticized the majority's reliance on political safeguards rather than judicial ones to protect state interests against federal encroachment, asserting it was insufficient in practice due to imbalances of power between national and local governments. Furthermore, she expressed concern about potential negative impacts on public accountability if citizens cannot clearly distinguish between responsibilities of different levels of government.