Heart of Atlanta Motel v. United States IRAC

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Heart of Atlanta Motel v. United States IRAC by Mind Map: Heart of Atlanta Motel v. United States IRAC

1. Facts

1.1. Parties

1.1.1. Heart of Atlanta Motel

1.1.2. United States

1.2. What Happened

1.2.1. Heart of Atlanta Motel owner refused to rent rooms to African Americans

1.2.2. The motel stated that they strictly provided local services

1.2.3. The motel is accessible to state and interstate highways

1.2.4. The motel advertised throughout the state and nation and frequently provided lodging for conventions

1.3. Procedural History

1.3.1. District court ruled the act did not violate the Constitution. The owner was prohibited from racial discriminating

1.3.2. Supreme court delivered same opinion. The Civil Rights Act is constitutional

2. Issue

2.1. Is there a constitutional violation by allowing the commerce clause and Civil Rights Act of 1964 to deprive businesses the ability to be selective of their customers?

3. Rule of Law

3.1. The commerce clause allows Congress to regulate interstate commerce.

3.2. The Civil Rights Act of 1964 prohibits businesses conducting interstate commerce to discriminate based on race.

4. Analysis/Application

4.1. How the rule of law is applied

4.1.1. Arguments

4.1.1.1. Plaintiff Argument - The motel provides accommodations for locals and does not affect interstate commerce. Therefore, commerce power is irrelevant for this case.

4.1.1.2. Defendant Argument - The motel discriminating against African Americans has negatively impacted their travel.

4.1.2. Although the motel's argument was that they were a local service, the court focused greatly on the motel's interstate business.

4.1.2.1. This is because at the time of the case the Commerce Clause only applied to interstate business.

4.1.3. It was also important to show that African Americans had difficulty traveling because of facilities providing accommodations were refusing to serve them.

4.1.3.1. The court goes a step further to include that this motel is not the only example of hardship African Americans were facing in their travels.

4.1.3.1.1. This was the highlight of the Civil Rights Act involvement.

4.1.4. It was compelling that the owner of the motel stated that he had refused to serve African Americans.

5. Conclusion

5.1. The court finds that Congress, the Commerce Clause, and the Civil Rights Act are constitutional.

5.1.1. Although the court is able to prove interstate commerce, it also addresses local commerce and the ability of Congress to directly see that as well.

5.1.1.1. "The power of Congress to promote interstate commerce also includes the power to regulate local incidents thereof" it continues to state that these incidents include those that have a "substantial and harmful effect upon that commerce."

6. Impact

6.1. Cases that have cited the holding

6.1.1. Willis v. Pickrick Restaurant

6.1.1.1. 3 African Americans claimed that the restaurant refused to serve them on account of their race.

6.1.1.1.1. The restaurant did not deny this claim.

6.1.2. U.S. v Morrison

6.1.2.1. A Virginia Tech student was raped and filed suit against one of her attackers, Morrison, via the Violence Against Women Act of 1994.

6.1.2.1.1. Morrison moved for dismissal stating that Congress did not have the authority under the Commerce Clause to enact this act.

7. Importance

7.1. Business professionals should care about this decision because it is a reminder that racial discrimination is unacceptable on interstate and intrastate commerce.

8. Influence

8.1. Business practices that have been influenced by the holding

8.1.1. Restaurants refusing to serve customers based on race were also influenced by the holding of this case and the Civil Rights Act.

8.1.1.1. Example: Katzenbach v McClung

8.1.2. Employment discrimination is influenced by this holding.