Heart of Atlanta Hotel v. United States 379 U.S. 241 (1964)

IRAC for Heart of Atlanta v. United States for Business Law Fall 2019

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Heart of Atlanta Hotel v. United States 379 U.S. 241 (1964) by Mind Map: Heart of Atlanta Hotel v. United States 379 U.S. 241 (1964)

1. FACTS

1.1. Parties

1.1.1. Appellant

1.1.1.1. Morton Rolleston

1.1.1.2. Heart of Atlanta Hotel, Inc.

1.1.2. Appellee

1.1.2.1. United States Supreme Court

1.2. What happened

1.2.1. The Heart of Atlanta Hotel was in violation of the Civil Rights Act of 1964 as it refused service to African American. The hotel owner, Morton Rolleston, sued declaring Congress had exceeded it's powers outlined by the Commerce Clause. The hotel received business from out of state guests at least 75% of the time and was located near Interstate 75 and 85, as well as local highways. In addition, the hotel had dozens of billboards as advertisements along these highways.

1.3. Procedural history

1.3.1. Case originated in Atlanta, GA

1.3.2. Was heard in the US District Court of Northern Georgia, upheld by Supreme Court

2. ISSUE

2.1. Has Congress overstepped the boundaries as outlined in Article I of the Commerce Clause?

2.2. Has the appellant had his Fifth and Thirteenth Amendment rights violated by being "forced" to serve African-Americans in his hotel?

3. RULE OF LAW

3.1. Title II of the Civil Rights Act of 1964

3.1.1. Bans the discrimination of race, color, gender, religion, or national origin in public places such as hotels, restaurants, and all other public accommodations engaged in interstate commerce

3.2. Fifth Amendment

3.2.1. Deprivation of property without due process of law

3.3. Thirteenth Amendment

3.3.1. "Involuntary servitude" may not exist in the US

3.4. Commerce Clause

3.4.1. Congress can regulate commerce between foreign nations, across several states, and Indian tribes. In this instance the court focuses on the Interstate Commerce Clause (Congress' ability to regulate commerce across states)

4. ANALYSIS/APPLICATION

4.1. Plaintiff

4.1.1. The appellant argued against Congress' ability to regulate private businesses and that they had overstepped as outlined by the Commerce Clause. He argued that by being forced to open his doors to all patrons and comply with the Civil Rights Act, his Fifth and Thirteenth Amendment rights were being violated. Morton Rolleston felt that by removing a race ban on his hotel he was being subject to deprivation of property without due process of law and ultimately felt it was an act of "involuntary servitude". The latter argument against Congress, he felt, was in direct violation of the Thirteenth Amendment

4.2. Defendant/Court

4.2.1. The movement of people between states is considered commerce and therefore falls within Congress' power and scope as laid out by the Commerce Clause. As such, Congress' can rule it unlawful to violate the Civil Rights Act, even in a private establishment as it negatively impacts interstate commerce. With this ruling, the violation of the Fifth and Thirteenth Amendments are therefore rendered invalid.

5. CONCLUSION

5.1. On December 14th, 1964 the Court ruled to uphold Title II of the Civil Rights Act of 1964 in conjunction with the Commerce Clause. Being that the hotel served mostly out-of-state patrons it was within the powers of Congress to regulate commerce between states. As such, the Heart of Atlanta Hotel was a place of public accommodation and therefore must abide by Title II of the Civil Rights Act of 1964.

5.2. The court also found that Title II of the Civil Rights Act of 1964 does not violate the Fifth Amendment when prohibiting racial discrimination in a place of public accommodation. Further, the grounds that the owner needed to comply to the Civil Rights Act did not constitute "involuntary solitude" and thus there was no violation of the Thirteenth Amendment.

6. IMPACT

6.1. United States v. Morrison, 529 U.S. 598 (2000)

6.1.1. The rape of a female student at Virginia Polytechnic by three male students. Issue is whether the VAWA is a valid exercise of Congress' power under the Commerce Clause. Used the ruling from Heart of Atlanta case to show that gender-motivated violence impacts interstate commerce and the national economy (women are deterred from taking certain jobs that require them to work in certain places, at certain times, and travel to certain locations), therefore it is well within the right of Congress to step in.

6.2. Katzenbach V. McClung (1964)

6.2.1. Is it within Congress' power to force private businesses to abide by Title II of the Civil Law Act? This case that occurred shortly after Heart of Atlanta v. US and used that as a precedent for the ruling. It was found that by banning those of race, color, religion, etc. would negatively impact that movement of merchandise and hinder national economics. In this case, blacks who were segregated from restaurants (specifically Ollie's BBQ) would be less likely to spend money in segregated establishments.

7. IMPORTANCE

7.1. Privately owned businesses can not practice discrimination or segregation under the Civil Rights Act if they negatively impact interstate commerce without expecting interference from Congress. This would impact restaurants, lodging, gas stations, what the law constitutes as public accommodation.

8. INFLUENCE

8.1. Foreign trade can be and is regulated by Congress. Any US company that has dealings with foreign entities is subject to the laws and regulations imposed by Congress.

8.2. This case can also affect companies like Amazon who do business all across the US via shipping.