Heart of Atlanta Motel, Inc. v. United States (1964)

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Heart of Atlanta Motel, Inc. v. United States (1964) by Mind Map: Heart of Atlanta Motel, Inc. v. United States (1964)

1. Facts

1.1. Parties

1.1.1. Appellant: Heart of Atlanta Motel, Inc.

1.1.1.1. Motel Owner: Moreton Rolleston

1.1.2. Appellee: United States

1.2. What happened

1.2.1. The Heart of Atlanta Motel, Inc. was located in Atlanta, Georgia; comprised of 216 rooms; was accessible by two interstate highways (75 and 85); and advertised in national media (billboards, magazines, conventions)

1.2.2. The Heart of Atlanta Motel, Inc. refused to rent any of its rooms to African Americans

1.3. Procedural History

1.3.1. The U.S. District Court for the Northern District of Georgia upheld the Civil Rights Act's constitutionality and prohibited the motel from racially discriminating against guests (refusing to accommodate African Americans)

1.3.2. Heart of Atlanta Motel, Inc. appealed to the Supreme Court and was granted a writ of certiorari

2. Issue before the Court

2.1. Whether it is constitutional for Congress, with the Civil Rights Act of 1964 (Title II) and the Commerce Clause, to prohibit racial discrimination in places of public accommodation?

3. Rule of Law

3.1. Civil Rights Act of 1964 (Title II)

3.1.1. The Civil Rights Act of 1964 (Title II) prohibits racial discrimination in public establishments

3.2. Commercial Clause

3.2.1. The Commerce Clause allows Congress to regulate interstate commerce (concerning more than one State)

3.2.2. Precedent: Gibbons v. Ogden

3.2.2.1. Does the Commerce Clause give Congress authority over interstate navigation?

3.2.2.1.1. Yes

3.3. 5th Amendment

3.3.1. The 5th Amendment prohibits self-incrimination, double jeopardy, and mandates due process of law

3.3.1.1. Due Process is the fair opportunity to be heard before the government takes away one's life, liberty, or property

3.4. 13th Amendment

3.4.1. The 13th Amendment prohibits slavery and involuntary servitude

4. Application

4.1. Appellant (Heart of Atlanta Motel, Inc.)

4.1.1. Civil Rights Act of 1964 (Title II) and Commerce Clause

4.1.1.1. Congress exceeded its power to regulate commerce (particularly a local, private business)

4.1.2. 5th Amendment

4.1.2.1. Congress violates the 5th Amendment because the motel is deprived of its right to choose its customers and operate its business as it wishes

4.1.2.1.1. This is a taking of the motel's liberty and property without due process and just compensation

4.1.3. 13th Amendment

4.1.3.1. Congress violates the 13th Amendment by requiring the motel to rent available rooms to African Americans

4.1.3.1.1. The motel is subjected to involuntary servitude because it is forced to rent parts of its property (rooms) to people whom it does not choose (African Americans)

4.2. Appellee (United States)

4.2.1. Civil Rights Act of 1964 (Title II) and Commerce Clause

4.2.1.1. Unavailable accommodations to African Americans significantly interferes with interstate travel, and hence, interstate commerce

4.2.1.1.1. Under the Commerce Clause, Congress has the power to remove obstructions and restraints to interstate commerce

4.2.2. 5th Amendment

4.2.2.1. The 5th Amendment does not forbid reasonable regulation on businesses

4.2.2.1.1. Using the intended meaning of the 5th Amendment, the "damage" to the motel does not constitute as a "taking"

4.2.3. 13th Amendment

4.2.3.1. Since the 13th Amendment is directed at ending slavery and involuntary servitude in places of public accommodation, the motel's claim is faulty

4.3. Court

4.3.1. Civil Rights Act of 1964 (Title II) and Commerce Clause

4.3.1.1. People are increasingly mobile, as millions of races are traveling from state to state

4.3.1.1.1. The lack of accommodations to African Americans discourages travel to a substantial part of the African American community

4.3.1.2. What is the power of Congress over Interstate travel and commerce?

4.3.1.2.1. Initially referring to Gibbons v. Ogden, the Court determines that Congress' power to regulate interstate commerce includes regulating local incidents of commerce that have a substantial impact on the interstate flow of goods

4.3.2. 5th Amendment

4.3.2.1. The law does not deprive the Appellant of liberty or property

4.3.3. 13th Amendment

4.3.3.1. The 13th Amendment is tied to the eradication of slavery and involuntary servitude

4.3.3.1.1. Forcing the Heart of Atlanta Motel, Inc. to offer motel rooms to African Americans is not "akin to African slavery" and does not count as involuntary servitude

5. Conclusion

5.1. Unanimous decision (9-0)

5.1.1. Majority decision (authored by Justice Clark)

5.1.1.1. The Civil Rights Act of 1964, applied to places of public accomodations to serve interstate travelers, is a valid exercise of the Commerce Clause

5.1.1.1.1. The motel's commerce affected more than one state, which allows Congress to exercise the Commerce Clause

5.1.1.1.2. Commerce Clause includes the power to regulate local activities that have a significant effect on interstate commerce

5.1.1.1.3. Racial discrimination in public accommodations impairs African Americans' ability to travel; this impacts interstate commerce and can be regulated because racial discrimination is of national interest

5.1.1.1.4. The 5th and 13th Amendments are not violated because the Appellant was not deprived of liberty nor property, and not subjected to involuntary servitude

5.1.2. Concurring Opinions (Justices Black, Douglas, and Goldberg)

5.1.2.1. Justice Black

5.1.2.1.1. The motel's racial discrimination policies have significant impact on interstate commerce especially due to the motel's wide reach of advertising

5.1.2.1.2. The motel's due process rights are not violated because

5.1.2.2. Justice Douglas

5.1.2.2.1. An impact on interstate commerce should not be a prerequisite for receiving protection against discrimination

5.1.2.2.2. A stronger and broader basis for Congress' authority is the 14th Amendment (Section 5), which grants all persons under equal protection of the law

5.1.2.3. Justice Goldberg

5.1.2.3.1. The majority opinion should rest upon both the Commerce Clause and 14th Amendment

6. Impact

6.1. Cases that have cited the holding

6.1.1. Lopez vs. United States

6.1.1.1. Is the 1990 Gun-Free School Zones Act, which forbids individuals from knowingly carrying a gun in a school zone, unconstitutional because it exceeds Congress' power under the Commerce Clause?

6.1.1.1.1. Yes, because the possession of a gun in a local school zone is not an economic activity that has a substantial effect on interstate commerce

6.1.2. Katzenbach v. McClung

6.1.2.1. Can the Civil Rights Act of 1964 prohibit a restaurant's racial discrimination against African Americans?

6.1.2.1.1. Yes, because of the interstate flow of food and restrictions on African American travelers

7. Importance

7.1. All businesses, both private and public, are required to service all races; discriminating against any race will have legal implications for a business

7.2. The case reaffirmed the Civil Rights Act of 1964, and therefore has wide impact across different industries, including hotels, restaurants, and other public establishments

8. Influence

8.1. There is less overt racial discrimination in public accommodations, and more initiatives to prevent racial biases

8.1.1. Fair hiring practices

8.1.1.1. It is illegal for employers to discriminate against job applicants due to their race, color, religion, or gender

8.1.2. Anti-discrimination policies and training within companies