Heart of Atlanta Motel v. United States (1964)

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

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, Moreton Rolleston, refused to rent rooms to African American customers

1.2.1.1. Violated the Civil Rights Act of 1964, which prohibited racial discrimination in establishments affecting interstate commerce

1.2.1.1.1. Owner found the Act unconstitutional, and claimed his hotel did not engage in interstate commerce

1.3. Procedural History

1.3.1. Owner filed suit to the federal district court on three (3) counts against the Civil Rights Act of 1964, Title II

1.3.1.1. Claimed Congress exceeded its Commerce Clause powers to regulate interstate commerce

1.3.1.2. Claimed his Fifth Amendment rights were violated, depriving him of the right to choose his customers and operate his business how he desired

1.3.1.3. Claimed his Thirteenth Amendment rights were violated, as he was subjected to involuntary servitude by being forced rent rooms to African Americans

1.3.2. District court found no violation to the Constitution, and prohibited the owner from discriminating based on race

1.3.3. Owner appealed, and the case went before the Supreme Court

2. Issue before the Court

2.1. Is the Civil Rights Act of 1964 unconstitutional as it pertains to interstate commerce and private businesses?

3. Rule of Law

3.1. The power of Congress over interstate commerce is not confined to the regulation of commerce among the states

3.1.1. Does this fall under jurisdiction of the federal government?

3.1.2. Does the law provide reasonable regulation of interstate commerce?

3.1.3. Does the law address an important purpose?

4. Application

4.1. The Commerce Clause establishes jurisdiction of the federal government over all interstate commerce

4.1.1. Owner claimed the Heart of Atlanta Motel operates in a "purely local character," and therefore the law did not apply to him

4.1.1.1. Owner advertised the motel nationally and maintained billboards throughout the state

4.1.1.2. 75% of guests were residents of other states

4.2. The Fifth Amendment establishes that a person shall not be deprived of property or liberty without due process of the law

4.2.1. Was the owner being forced to open his property to the public without compensation?

4.2.1.1. African American clients would compensate him the same way white travelers did

4.2.1.2. The Fifth does not forbid reasonable regulation of interstate commerce

4.3. The Thirteenth Amendment abolishes involuntary servitude

4.3.1. Was the owner being forced into servitude?

4.3.1.1. Owner ran his establishment voluntarily

4.3.1.2. Serving customers he did not want to serve does not constitute servitude

5. Conclusion

5.1. The US Supreme Court declared the Civil Rights Act of 1964 constitutional

5.1.1. Valid exercise of Congress' as applied to a public establishment serving interstate travelers

5.1.1.1. The Heart of Atlanta Motel was charged with violating the Civil Rights Act, Title II

5.2. The Court found no evidence the Title II prohibition violated the Fifth or Thirteenth Amendments

6. An example of racial segregation imposed by the states in public facilities, violating the US Constitution

6.1. Module 2