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

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

1. Conclusion

1.1. United States Supreme Court upheld the District Court ruling which prohibited the owner from racial discrimination.

1.1.1. Congress has the power to regulate local businesses if they conduct interstate commerce

2. Facts

2.1. Parties

2.1.1. United States - Appellee/Defendant

2.1.2. Heart of Atlanta Motel - Appellant/Paintiff

2.2. What Happened

2.2.1. Passage of Civil Rights Act of 1964 explicitly prohibits discrimination based on race in"establishments affecting interstate commerce"

2.2.2. Heart of Atlanta, a 216-room motel located in Atlanta, Georgia, by accepting business from outside the state (with 75% of the guests were residents of other states) participated in interstate commerce.

2.2.3. The owner of the Heart of Atlanta Motel, in violation of the Civil Rights Act of 1964, declined to rent rooms in his establishment to African Americans.

2.2.4. The motel owner attempted to declare the Civil Rights Act unconstitutional because the congress exceeded its constitutional authority by enacting the statute. The owner stated that his motel is local rather than interstate

2.3. Procedural History

2.3.1. The district court ruled that the act was not unconstitutional and prohibited the owner from discriminating on the basis of race.

2.3.2. The motel owner appealed and the case ultimately proceeded to the United States Supreme Court.

3. Rule of Law

3.1. Congress passed the Civil Rights Act of 1964 which prohibited race based discrimination.

3.2. The Supreme Court upheld the Civil Rights Act of 1964. Congress can regulate business activity that is purely local, if any part of the activity affects interstate commerce, if the activity has a substantial effect on interstate commerce.

4. Analysis/Application

4.1. Plaintiff (Motel Owner)- 1964 civil Rights Act exceeded the authority granted to Congress over interstate commerce.

4.1.1. The motel owner stated fifth amendment empowered him to select customers. The Civil Rights Act violates his civil liberty

4.1.1.1. The motel owner also stated that the Civil Rights Act violates the rights granted to him under the thirteenth amendment forcing him to perform "involuntary servitude" by forcing him to rent rooms to African Americans.

4.2. Defendant (United States)- The transportation of passengers in interstate commerce makes any establishment interstate and as such, within the regulatory power of Congress, under the commerce clause of the Constitution.

4.2.1. The Fifth Amendment does not forbid reasonable regulation of interstate commerce.

4.2.1.1. The Thirteenth Amendment applies primarily to slavery and did not apply in this context.

4.3. U.S. Supreme Court- Congress acted well within its authority under the Commerce Clause in passing the Civil Rights Act of 1964.

4.3.1. The US Supreme Court concluded that the motel conducts interstate commerce based on the facts (The motel advertised nationally and accepted convention trade from outside the state were residents of the other states). In addition, the motel was also located near Interstates 75 and 85 as well as two major Georgia highways, So the business clearly affected interstate commerce.

4.3.1.1. Prohibition of racial discrimination in public places does not result in deprivation of property without due process and therefore does not violate the fifth amendment.

4.3.1.1.1. Prohibition of racial discrimination in public places does not violate the Thirteenth Amendment as being "involuntary servitude".

5. Issue before the court

5.1. Did Congress exceed its Commerce Clause powers under Civil Rights Act 1964, by taking away rights of motel to select their customers?

6. Impact

6.1. KATZENBACH V. MCCLUNG, 1964

6.1.1. This case was similar to Heart of Atlanta versus United States. Ollie McClung, a family-owned restaurant owner in Birmingham, Alabama, used an argument similar to Heart of Atlanta motel owner and initially won in the District Court. However, upon appeal, Supreme Court upheld the Civil Rights Act of 1964 and stated that Congress can regulate business activity, if any part of the activity affects interstate commerce.

6.2. GONZALES V. RAICH, 2005

6.2.1. In Gonzales v. Raich, the Court ruled that, under the Constitution's Commerce Clause, Congress can criminalize cannabis production even if states have legalized its use for medical purposes. The Court held that Congress may regulate intrastate activity where there may be an impact on interstate commerce.

7. Influence

7.1. Health Care (especially hospitals)

7.1.1. Hospitals can not deny patient care to any individual based on their race, color, religion or gender. Each patient has the right to healthcare.

7.2. Any business with an online component/store

7.2.1. Internet based businesses may be small in scale and have local flair; however, any business with an online store or component inherently has to abide by laws that regulate interstate commerce.

8. Importance

8.1. The decision has validated the Civil Rights Act of 1964 commerce clause and as such, prohibits discrimination based on race, color, national origin, religion, or gender in all public accommodations. If the outcome of this case would have been different then each state could have had their own laws which may have been discriminatory based on race or religion.