Heart of Atlanta Motel v. United States 379 U.S. 241 (1964): an IRAC Case Analysis

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

1. Rule of Law

1.1. Civil Rights Act of 1964 & the Commerce Clause of US Constitution

1.2. 14th Amendment (1868)

1.2.1. Guaranteed "all persons born or naturalized in the US"(including African Americans) US Citizenship, legal and civil rights

1.3. 13th Amendment (1865)

1.3.1. The abolishment of "slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted" in the US

1.4. 5th Amendment (1791)

1.4.1. Includes rights to "due process of law" (any citizen charged with a crime has a right to a fair trial through the judicial system) and no person should be deprived of liberty

2. Facts

2.1. Parties

2.1.1. Plaintiff

2.1.1.1. Heart of Atlanta Motel

2.1.2. Defendant

2.1.2.1. United States

2.2. What Happened

2.2.1. In the 1950s, state laws that supported racial segregation in public facilities (churches, schools, etc.) were deemed unconstitutional by the US Supreme Court

2.2.2. Later, the Civil Rights Act of 1964 prohibited racial discrimination on the basis of race, color, religion, sex, or national origin, required equal access to public places and employment

2.2.2.1. The comprehensive legislation included 11 titles and became the hallmark of the American Civil Rights

2.2.2.1.1. Specific to this case is Title II:

2.2.3. Owner of Heart of Atlanta Motel, Moreton Rolleston, refused to rent rooms to African Americans

2.2.3.1. 216 rooms available to transient guests

2.2.3.2. Two blocks from downtown, readily accessible to highways 75 & 85

2.2.3.3. Owner used national advertising medias (magazines & Billboards) to solicit business from in and out of state customers

2.2.4. Initially, Rolleston challenged the Civil Rights Act in the U.S. District Court for the Northern District of Georgia and did not win the case.

2.3. Procedural History

2.3.1. Heart of Atlanta Motel, Inc. v. United States, 231 F. Supp. 393 (N.D. Ga. 1964)

2.3.1.1. Judgment for defendant (US)

2.3.1.1.1. District Court found Title II constitutional

2.3.1.2. Heart of Atlanta was ordered not to racially discriminate further

2.3.2. Heart of Atlanta appealed and the US Supreme Court agreed to hear the case.

3. Issues

3.1. Whether Congress exceeded its power to regulate commerce through the Civil Rights Act of 1964.

3.1.1. Or in other words

3.1.1.1. Is prohibiting racial discrimination constitutional per the commerce clause?

3.2. Whether Congress violated section 5 of the 14th amendment by forcing the owner about who he can or cannot choose as his customers

3.3. Whether Congress violated the 13th Amendment by a form of "involuntary servitude" where the motel owner is forced to open his doors to African Americans

3.4. Whether Congress violated 5th amendment (due process) by denying (charging) the motel owner to run his business as he sees fit.

4. Analysis/Application

4.1. Plaintiff

4.1.1. Rolleston claimed that

4.1.1.1. Congress (who enacted the Civil Rights Act of 1964) exceeded their authority under the commerce clause

4.1.1.1.1. Rolleston's motel business is of "local character", so the federal statute does not apply to him.

4.1.1.2. Congress enforcing the motel owner to make business decisions based on a certain type of customer is a form of violation of the 13th Amendment (via involuntary servitude)

4.1.1.3. Congress did not provide Rolleston due process of the law and deprived the motel owner from his liberty of running his business as he sees fit (via 5th amendment)

4.2. Defendant

4.2.1. Congress does have the authority under the commerce clause to enact the Civil Rights act of 1964

4.2.1.1. Restrictions placed on African Americans did affect interstate commerce

4.2.2. The 5th Amendment was not violated

4.2.2.1. Rolleston was not deprived of liberty because he was still being financially compensated from his business

4.2.3. In reference to "involuntary servitude" of the 13th Amendment, it does not apply to this case because it isn't slavery related.

4.3. Court

4.3.1. The congress does have power to promote interstate commerce

4.3.1.1. This includes the power to regulate local activities in both states of origin and destination

4.3.1.1.1. The Heart of Atlanta motel's proximity to interstate highways was highlighted to support the defendant's claim

4.3.2. The discrimination of African Americans does affect interstate commerce

4.3.2.1. Americans, in general, were more mobile. The discrimination affected commerce because African Americans would need to travel further for lodging

4.3.2.1.1. 75% of Heart of Atlanta Motel's customers were out-of-state residents

4.3.3. There is federal interest to stop racial discrimination (14th amendment)

5. Conclusion

5.1. The Supreme court affirmed with the lower court's judgement (9:0 vote): Congress was within its power to prohibit racial discrimination (via Civil Rights Act of 1964) by motels

5.1.1. The Rule applies because

5.1.1.1. Congress has power over interstate commerce (according to Commerce Clause).

5.1.1.1.1. Why? Interstate movement of person is considered "commerce" because it concerns more than 1 state

6. Impact

6.1. Masterpiece Cakeshop, Ltd. v. Colo. Civil Rights Comm'n, 138 S. Ct. 1719 (2018)

6.1.1. A baker declined to bake a wedding cake for a same sex marriage on the basis that he would be forced to involuntarily use his artistic skills that is inconsistent with his religious beliefs.

6.1.1.1. Originally, the state ruled the baker violated the anti-discrimination act (discrimination in a place of public accommodation )

6.1.1.1.1. The decision was later reversed by the Supreme court citing that the state civil rights commission violated the first amendment's free exercise clause

6.2. Hurley v. Irish-American Gay, 515 U.S. 557 (1995)

6.2.1. Parade organizers denied a gay organization's application to march in their parade. An original court ruling concluded that this violated the gay organization's freedom of speech under Mass. Gen. Laws

6.2.1.1. This Supreme Court case was the appeal to the prior judgment. The lower court judgement was reversed because the "requirement to admit a parade group expressing a message not of the private organizers' own choosing violated the organizers' 1st amendment rights"

6.2.1.1.1. Heart of Atlanta Motel was used to acknowledge that we are not allowed to discriminate. In this case, it was shown that no individual was denied (or discriminated) to participate. The gay organization's "message" was contrary to the parade organizer's message; hence, the original ruling was overturned.

7. Importance

7.1. As a business professional, in every business decision

7.1.1. I should ensure that the decision complies with state and federal laws (including the different interpretations and uses of Heart of atlanta motel v US)

7.1.2. I should consider that the commercial clause is a means to combat discrimination legally

7.1.3. It goes without saying, but I will always uphold an anti-discrimination stance

8. Influence

8.1. Two business practices that are influenced by the holding

8.1.1. Whenever one applies to a new job

8.1.1.1. There is usually a section informing the applicant that the company does not tolerate discrimination

8.1.2. Fair Housing & Equal Opportunity

8.1.2.1. Laws that "aim to eliminate housing discrimination, promote economic opportunity, and achieve diverse, inclusive communities"

8.1.2.1.1. HUD.gov / U.S. Department of Housing and Urban Development (HUD)

8.1.2.2. Property managers and owners cannot discriminate (or deny applications)

9. M2: IRAC Case Analysis MindMap | Business Law: Section 31 | Prof. S. Lee

10. Student: Kimberly Jaramillo | JHU Carey Business School | Spring II 2019