Heart of Atlanta Motel v. United States 379 U.S. 241 (1964)

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Heart of Atlanta Motel v. United States 379 U.S. 241 (1964) by Mind Map: Heart of Atlanta Motel v. United States 379 U.S. 241 (1964)

1. FACTS: Who, What and Where

1.1. Parties

1.1.1. Plaintiff (Appellant): Heart of Atlanta Motel

1.1.1.1. Heart of Atlanta was a large (216 room) establishment of public accomodation, situated in the middle of the city's business district, which advertised nationally, and had on average out-of-state residents accounting for 75% of its clientele.

1.1.2. Defendant (Appellee): United States Government

1.1.3. Court: Original Suit: Federal District Court Court of Appeal: U.S. Supreme Court, Earl Warren, Chief Justice

1.2. What Happened: The Plaintiff had a standing business practice of renting rooms only to "white" clientele, and of refusing to accept people of color (primarily those of African-American descent) as customers.

1.2.1. 1n 1964, Congress passed the Civil Rights Act of 1964 (CRA 1964).

1.2.2. With the passage of the CRA 1964, business practices such as those conducted by the Plantif were deemed illegal.

1.2.3. Wishing to continue the practice of selecting clients on the basis of race, the Plaintiff sued the U.S. Government to have the CRA 1964 declared unconstituional.

1.2.4. The Plaintiff also contended its business was purely local in nature and not subject to federal regulation.

1.3. Procedural History

1.3.1. Original suit brought in Federal District Court and reviewed by a three-judge panel.

1.3.1.1. The District Court ruled the CRA 1964 valid and that the business was subject to it.

1.3.1.2. Additionally, the District Court supported the Defendent's counter claim (which was that the Plaintiff had to accept clientele regardless of race) and ordered the Plaintiff to immediately start letting rooms to those of the Negro race.

1.3.2. Appeal brought to U.S Supreme Court. Argued October 4, 1964. Decided December 13, 1964. Opinion written by Justice Tom C. Clark.

1.3.2.1. The textbook misidentifies the Justice as "CLARKE."

2. ISSUE: Did the United States Government have the right under the Constitution to insist private business accept clientele and customers regardless of race?

3. RULE OF LAW: The Plaintiff challenged the constitutionality of the Civil Rights Act of 1964 on three points.

3.1. The Commerce Clause

3.2. The Fifth Amendment

3.3. The Thirteenth Amendment

4. APPLICATION and ANALYSIS

4.1. Plaintiff's Case: The U.S. Government does not have the right to make us (or any other establishment of public accomodation) change our business practices. And, in fact, the CRA 1964 is unconstitutional under the...

4.1.1. Commerce Clause: Argued that their business was of a purely "local" nature, and thus, the Commerce clause did not apply.

4.1.2. Fifth Amendment: Argued that forcing them to change their business practices and accept clientele without regard to race meant the government was unreasonably impinging on their liberty and property.

4.1.3. Thirteenth Amendment: Argued that enforced compliance with a federally enacted law constituted "involuntary servitude."

4.1.3.1. Whether a white supremicist arguing for the continuation of a Jim Crow practice under the auspice of the Amendment that outlawed slavery is an act of deliberate irony may be debated. Such an argument, however, may have contributed to the labeling parts of the suit as "frivolous."

4.2. Defendant's Case: "The U.S. Government has the constitutional authority to enact and enforce such a law. "

4.2.1. Commerce Clause: The Plaintiff engages in interstate commerce. The U.S. Government has the right to regulate such commerce.

4.2.2. Fifth Amendment: The regulation of business under the constituionally valid premise of interstate commerce does not equate to "taking" property.

4.2.3. Thirteenth Amendment: The Amendment was intended to abolish slavery, not prevent regulation of interstate commerce.

4.3. Court's Deliberation: The court reviewed the facts and precedent. They focused on a few key areas in determining the constitutionality of the CRA 1964.

4.3.1. What is the definition of interstate commerce and how does it apply to this business and others of its kind (the hotel industry)?

4.3.1.1. The Court noted, that in addition to advances in transportation expanding what businesses may be considered to engaged in interstate commerce, the government has a compelling interest in making sure businesses of public accomodation behave comparably across the country.

4.3.2. Does this business (specifically and as an industry) conduct interstate commerce?

4.3.2.1. Yes.

4.3.3. Was the legislation appropriately drafted, reviewed, supported and enacted, as defined by the processes of the Constitution?

4.3.3.1. Yes. The Court, however, declined to consider the Senate Commerce Committee's intent of restorative justice in reviewing the validity of the CRA 1964. They stated they were weighing the case solely on the interstate commerce factors.

4.3.4. Which prior decisions and laws relate to this one? Do the support the Plaintiff's or Defendent's postitions

4.3.4.1. Several precedents were reviewed. Of note: the commentary on the Civil Rights Act of 1875, which had been ruled unconstituional under the 1883 Civil Rights Cases holding. The current Court noted the CRA 1875 did not at that time appropriately define interstate commerce. The current CRA 1964 did define interstate commerce in a valid manner.

5. CONCLUSION: The Supreme Court held the CRA 1964 was valid. Justice Tom C. Clark wrote the majority opinion. Justices Black, Douglas and Goldberg each wrote concurring opinions.

5.1. Commerce Clause: The Court held that "interstate commerce" was appropriately defined and applied in the legislation. Further, this business and others of its kind are subject to regulation under it. Finally, it was held that businesses such as this particular one must accept clients regardless of race.

5.1.1. Justice Black's concurring opinion forbid the Plaintiff from continuing to discriminate amongst clients on the basis of race.

5.2. Fifth Amendment: What the Defendant said.

5.3. Thirteenth Amendment: What the Defendant said.

6. IMPLICATIONS: How this holding has affected law and business in an ongoing way.

6.1. Impact: Cases citing this holding

6.1.1. Camps Newfoundland/Owatonna v. Town of Harrison, ME.

6.1.1.1. Summary of case: A not-for-profit camp in Maine was subject to property tax, despite the charitable nature of both its incorporation and services. The camp served primarily out-of-state residents. The state of Maine held that state tax relief was only for non-profits serving local residents. The camp sued for relief of taxes, claiming it was engaged in interstate commerce.

6.1.1.2. Rule of law: The case was argued under the Commerce Clause.

6.1.1.3. Analysis: In the majority opinion, Justice Souter cited Heart of Atlanta Motel v. U.S. four times. Among the points he raised: Camps, like hotels, are lodging establishments, and thus, subject to the dormant Commerce cCause just as other places of public accomodation were.

6.1.1.3.1. As an observation, Justice Souter's citation of Gibbons v. Ogden, and the Court's opinion there that commerce was the primary factor unifying the U.S. under the Constituion, puts the quote "The business of America is business" into a new light for this student.

6.1.1.4. Relevance to business: Not-for-profit corporations may seek local tax relief even if they serve nonlocal clients. With the growth of charitable activities conducted by for-profit entitites, it is also interesting to consider how those endeavors may offset local tax liability.

6.1.2. Masterpiece Cakeshop v. Colorado Civil Rights Commission.

6.1.2.1. Summary of case: A same-sex couple was getting married. They requested Masterpiece Cakeshop make their wedding cake. The owner refused, on the basis of a religious belief that same-sex marriage was morally wrong. The business owner also told the couple the bakery would make them anything else for any other reason.

6.1.2.2. Rule of law: This case was argued under the First Amendment, rather than the Commerce Clause.

6.1.2.3. Analysis: In a concurring opinion, Justice Elena Kagan cites Heart of Atlanta Motel v. US. Justice Kagan's opinion points out that the government can not regulate speech, and the court's precedent is to allow speech which many may find degrading or objectionable. Her citation points out that had Colorado originally prosecuted Masterpiece on the precedents of Heart of Atlanta, JEB vs. Alabama, etal, instead of for citing Masterpiece's religious objection to same-sex marriage, different tests of validity could have been applied.

6.1.2.4. Conclusion: Masterpiece Cakeshop was within its rights to decline to make a cake for the couple's wedding on the basis of freedom of speech and religious expression.

6.1.2.5. Relevance of decision to business: While this decision was "narrowly" decided -- ie, applicable only to this business and suit, not those in general-- it serves to leave the door ajar to businesses to deny service if such denial is presented as an act of religious expression. As questions of providing coverage for various health-care services continue to arise, the relevance of this case as justification for denial of birth control and other women's health services grows in importance.

6.1.2.5.1. As purely an observation, those wishing to advance protections for various classes should remember that, in general, the Constitution allows the government to regulate what citizens do, but generally protects what citizens may say. So the reasons for regulation and enforcement need to be chosen carefully.

6.2. Importance: Why businesses today need to consider this holding

6.2.1. How will interactions between employees and customers be perceived? Will my company be held liable for actions of a specific employee? How can a manager ensure all customers are being provided fair and equal service? How does a manger prevent specific employees from bringing personal bias (perhaps unconscious) into their dealings with customers?

6.3. Influence: Business practices affected by the holding

6.3.1. Positive influence: Employees are now trained to interact with customers based on the customer's needs, not the employee's personal perspectives. Additionally, senstivity training may be provided when it becomes evident that employees are allowing unconscious bias to affect their interactions with customers

6.3.2. Negative influence: Due to this and other similar rulings, some businesses shut down rather than change their practice. One such business was the dining establishment owned by Lester Maddox. Maddox went on to become Governor of Georgia.