1. BACKGROUND
1.1. In the 1950s, the United States Supreme Court ruled that racial segregation imposed by the states in school systems and other public facilities violated the Constitution. Private businesses were not affected until passing of the Civil Rights Act of 1964, that prohibited racial discrimination in "establishments affecting interstate commerce."
2. ISSUE
2.1. Whether the Civil Rights Act of 1964 is unconstitutional?
3. FACTS
3.1. Parties
3.1.1. Moreton Rolleston, The owner of the Heart of Atlanta Motel, Plaintiff/Appellant
3.1.2. United States, Defendant/Appellee
3.2. What happened
3.2.1. In violation of the Civil Rights Act, the owner of the Heart of Atlanta Motel, Moreton Rolleston, refused to rent rooms to African Americans claiming that his business was not engaged in the interstate commerce but was of "purely local character." However, the motel was easily accessible from the state and interstate highways, the owner advertised nationally, and accepted convention trade from outside the state (75% of guests were residents of other states).
3.3. Procedural history
3.3.1. In 1964, Mr. Rolleston filed a suit in the US District Court of North Georgia United States to challenge the constitutionality of Section II of the Civil Rights Act, which barred segregation in all public accommodations on the basis that the practice inhibited the interstate movements of people and products. The Plaintiff sought declaratory judgment and injunctive relief from the public accommodations provisions of the Civil Rights Act. The court upheld the law and ordered Mr. Rolleston to admit black patrons within twenty days.
3.3.1.1. Mr. Rolleston appealed, the case was ultimately heard by the United States Supreme Court and in December, 1964 lower court decision was affirmed.
4. ISSUE BEFORE THE COURT
4.1. Whether the Civil Rights Act of 1964 violated the Constitution by banning racial segregation in "establishments affecting interstate commerce?" Whether the Congress exceeded its Commerce Clause power by depriving the motel owner of the right to choose its customers?
5. RULE OF LAW
5.1. United States Constitution and Congressional Authority
5.1.1. Article I, Section 8, Clause 3; Commercial Clause
5.1.1.1. Fifth Amendment
5.1.1.1.1. Thirteenth Amendment
5.2. Civil Rights Act of 1964
5.2.1. Title II
6. ANALYSIS
6.1. The Appelants's Arguments
6.1.1. The Congress exceeded its power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes"(Article I, sec. 8). The Appelant's rights were violated by applying the Civil Rights Act provisions to the allegedly "purely local business."
6.1.1.1. The Civil Rights Act violated the Fifth Amendment by depriving the business owner of the "right to choose ... customers and operate... business as <he> wishes;" thus taking away liberty and property without due process of law and a just compensation."
6.1.1.1.1. Congress exceeded the power by requiring the Appellant to rent available rooms to Negroes against the will, thus subjecting him to "involuntary servitude in contravention of the Thirteenth Amendment."
6.2. The Appellee's Arguments
6.2.1. Article I, Sec. 8 of the US Constitution permits the Congress to regulate interstate commerce. The Appelant's business advertised nationally and accepted guests from other states. In fact, the majority of his guests were residents of the other states, thus satisfying the definition of the interstate commerce. Inability of the African Americans to find suitable accommodations interfered significantly with the interstate travel and, under Commercial Clause, the Congress had power to remove restraints and obstructions.
6.2.1.1. The Fifth Amendment does not forbid reasonable regulation. The Appellant's rights were not violated as the due process provision did not apply in this case and the Appellant was not deprived of his property as consequential damage does not constitute a "taking" within the meaning of that amendment.
6.2.1.1.1. "The Thirteenth Amendment claim fails because it is entirely frivolous to say that an amendment directed to the abolition of human bondage and the removal of widespread disabilities associated with slavery places discrimination in public accommodations beyond the reach of both federal and state law."
6.3. Court ruling
6.3.1. The court concluded that "the action of the Congress in the adoption of the Act as applied here to a motel which concededly serves interstate travelers is within the power granted it by the Commerce Clause of the Constitution... It may be argued that Congress could have pursued other methods to eliminate the obstructions it found in interstate commerce caused by racial discrimination. But this is a matter of policy that rests entirely with the Congress, not with the courts. Affirmed." In this case, the court slightly expanded the law by extrapolating it to the prevention of the general obstruction of commerce, not only travel related.
7. CONCLUSION
7.1. The Supreme Court affirmed the decision of the lower court and deemed provisions of the Civil Rights Acts of 1964 constitutional. The Heart of Atlanta motel was prohibited discrimination on the basis of race, in conjunction with the Fourteenth Amendment and equality clause.
8. IMPACT
8.1. Katzenbach v. McClung (1964). The United States Supreme Court case in which the Court unanimously held that Congress acted within its power under the Commerce Clause of the United States Constitution in forbidding racial discrimination in restaurants as this was a burden to interstate commerce.
8.1.1. US v Jean MARTIGNON (2004). The defendant was indicted by the federal grand jury for selling unauthorized recordings of live performances and petitioned to dismiss the indictment under the claim that anti-bootlegging statute is unconstitutional because it was too broad. The court agreed with this reasoning and affirmed that copyright legislation did not fall under the Commerce Clause.