1. Impact
1.1. Hodel v. Virginia Surface Mining, 452 U.S. 264 (1981)
1.1.1. Surface Mining Control and Reclamation Act of 1977
1.1.1.1. Protects environment from adverse effects of surface mining
1.1.2. Coal producers sued Act as unconstitutional
1.1.3. U.S. District Court upheld the Act as constitutional under the commerce clause
1.1.3.1. Cited Heart of Atlanta Motel vs U.S.
1.2. United States v. Gulf-State Theaters, Inc., 256 F. Supp. 549 (N.D. Miss. 1966)
1.2.1. Attorney General filed against a pattern of racial discrimination denying entry of African Americans to a chain of movie theaters in Mississippi
1.2.1.1. Cited Heart of Atlanta Motel vs U.S.
1.2.2. Defendants claim that while the commerce clause applies to hotels and restaurants, it does not apply to motion picture theaters
1.2.2.1. Court rejects this argument and sustains that the motion picture theaters do engage in interstate commerce
2. Importance
2.1. Most modern businesses can be judged to engage in interstate commerce in some way
2.1.1. Supply chains
2.1.2. Customers
2.1.3. Shareholders/owners
2.2. The U.S. congress has the power to regulate business under the commerce clause
3. Influence
3.1. The Civil Rights Act of 1964 is a key piece of legislation that nearly all businesses adhere to today.
3.1.1. Most types of discrimination by mainstream businesses are not tolerated or accepted in any way
3.2. Congressional power to regulate environmental concerns through the use of the commerce clause is widely accepted
3.2.1. Most modern businesses at least claim to be working to better the environment - Many are doing more than that
4. Facts
4.1. 1950s Civil rights laws only affected public facilities
4.2. Civil Rights Act of 1964
4.2.1. Prohibits racial discrimination in "Establishments affecting interstate commerce"
4.3. Heart of Atlanta Motel
4.3.1. National advertising
4.3.2. Accessible to state and interstate highways
4.3.3. Statewide bilboards
4.3.4. Hosts out of state conventions
4.3.5. 75% of guests were residents of other states
4.4. Owner
4.4.1. Claims Hotel is "of a purely local character"
4.4.2. Brings suit that Civil Rights Act of 1964 is unconstitutional
4.4.2.1. Owner Appealed
4.4.2.2. Winds up at U.S. Supreme Court
4.4.2.3. District Court ruled that Civil Rights Act of 1964 was not unconstitutional
5. Issue
5.1. Whether the Heart of Atlanta Motel's right as a private establishment to prohibit rental of rooms based upon racial discrimination is being violated by the Civil Rights Act of 1964
6. Rule
6.1. Commerce Clause
6.1.1. Congress is permitted to regulate commerce
6.1.1.1. With foreign nations
6.1.1.2. Among the Several States
6.1.1.3. With Indian Tribes
7. Analysis
7.1. Public interest
7.1.1. Freedom of interstate travel and commerce
7.2. The Heart of Atlanta Motel's right as a private entity to select renters based upon racial discrimination does not outweigh the public interest of freedom of interstate travel and commerce
7.2.1. Freedom of interstate commerce > Private right to discriminate
7.3. Hotels impact commerce between the states
7.3.1. If an individual can not find a room to stay they might not travel and do their out of state business.
7.3.2. Heart of Atlanta Motel clearly hosts out of state visitors based upon facts of the case
7.4. Heart of Atlanta Motel claims that their hotel does not impact interstate commerce and therefore the federal government can not create a regulation that denies their rights as a private establishment
8. Conclusion
8.1. The U.S. Supreme Court upheld the lower courts' decisions that the Act did not violate the constitution
8.1.1. Heart of Atlanta Motel is subject to the Commerce Clause
8.1.2. Does not have an individual right to discrimination because it impacts the greater government interest of free interstate travel and commerce