Heart of Atlanta Motel v. United States Case Analysis

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

1. 1. Facts

1.1. Parties

1.1.1. Heart of Atlanta Mote, Plantiff

1.1.2. The United States Government, Defendant

1.2. What Happened?

1.2.1. The Heart of Atlanta Motel refused to rent rooms to African Americans. This occurred after the Civil Rights Act of 1964 which banned this practice by prohibiting racial discrimination in public places.

1.2.2. Heart of Atlanta Motel sued the United State of America to find the Civil Rights Act of 1964 unconstitutional

1.3. Procedural History

1.3.1. Initially, the case in the Northern District Court of Georgia in 1964 the Court ruled against Heart of Atlanta Motel

1.3.1.1. The Court decided that the Civil Rights Act of 1964 was constitutional and prohibited the Heart of Atlanta Motel to discriminate based on race. The Motel filed for an appeal.

1.3.2. The Appeals court upheld district court ruling.

1.3.3. The Plaintiff decided to appeal the case to the Supreme Court

2. 2. Issues

2.1. Does the Civil Rights Act of 1964 under the commerce clause violate the constitution by taking away the motel's the right to choose its customers?

2.2. Are the powers given to Congress under the Commerce Clause enough to allow them to force private businesses to abide by Title II of the Civil Rights Act?

3. 3. Rule of Law

3.1. US Constitution

3.1.1. Article I, Section 8, of the US Constitution (Commerce Clause) gives Congress the ability to regulate interstate commerce

3.1.1.1. Under the Commerce Clause, the Civil Right Act of 1964, Section 201(a) states that all people are entitled to accomodations of any place of public accomodation without discrimination as to color

3.1.2. 5th Amendment

3.1.2.1. private property shall not be taken for public use, without just compensation

3.1.3. 13th Amendment

3.1.3.1. Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.

4. 4. Analysis/Application

4.1. Plaintiff

4.1.1. The Motel argued that the Civil Rights Act violated the 5th Amendment by taking private property for public use without just compensation

4.1.2. The Motel argued that the Civil Rights Act violated the 13th Amendment by forcing "involuntary servitude"

4.2. Defendant

4.2.1. The court observed that 75% of the Heart of Atlanta Motel's customers came from out-of-state, and the Court found that the business clearly affected interstate

4.2.1.1. The 5th Amendment does not forbid reasonable regulation of interstate commerce

4.2.2. The 13th Amendment involves slavery and does not place issues of racial discrimination in public beyond the reach of the Federal and state law

4.3. Court

4.3.1. The US Supreme Court ruled in favor of the United States, upholding the ruling and injunction filed by the US District Court

5. 5. Conclusion

5.1. The Civil Rights Act of 1964 did not violate the Constitution.

5.2. Heart of Atlanta Motel must comply with Civil Rights Act of 1964

5.3. Congress is within it's reach to force interstate commerce to abide by Title II of the Civil Rights Act

6. 6. Impact

6.1. United States v. Lopez (1995)

6.1.1. High-school student brought gun on school campus

6.1.2. The Supreme Court held that the federal Gun-Free School Zones Act of 1990, which banned possession of handguns near schools, could not be regulated by congress because it did not have a substantial impact on interstate commerce. The case was used to define interstate commerce

6.2. United States v. Morrison (2007)

6.2.1. Marignon (defendant) charged with unauthorized recordings of live performances and Heart of Atlanta v. U.S. was cited as a way the court can regulate interstate commerce

7. 7. Importance

7.1. This case was in midst of the Civil Rights Movement. If the ruling had been with the Plaintiff, the Civil Right Movement would have suffered major setbacks.

7.1.1. Civil Rights Act of 1964 was significant in dismantling the Jim Crow laws

7.2. Without this case, Business professionals could potentially still have the ability to refuse service/goods to a person based on their race.

8. 8. Influence

8.1. Katzenbach v. McClung, 379 U.S. 294 (1964)

8.1.1. 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.

8.1.2. This case went on at the same time as Heart of Atlanta Hotel v US.

8.2. Telescope Media Group v. Lindsey (2017)

8.2.1. The Larsens filed suit in federal court to protect their right to create art that is consistent with their beliefs.

8.2.2. This case was influenced by Heart of Atlanta v. US due to it's anti discrimination nature