1. Relevant Law
1.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) "[The Congress shall have Power] To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes;"
1.2. Fifth Amendment, US Constitution "No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger; nor shall any person be subject for the same offence to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation."
1.3. Thirteenth Amendment, US Constitution Section 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." Section 2 "Congress shall have power to enforce this article by appropriate legislation."
2. Analysis
2.1. Plantiff
2.1.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) The powers, mandates, and enforcement of the Civil Right Act exceed those permitted under Congress' authority over interstate commerce.
2.1.2. Fifth Amendment, US Constitution Enforcement of the Civil Rights act in this case violates the plaintiff's constitutional rights to run his business as he chooses, and constitutes a seizing of his property without just compensation and due process under the law.
2.1.3. Thirteenth Amendment, US Constitution Being forced by the government to rent rooms to African Americans constitutes enforcement of involuntary servitude, in violation of the thirteenth amendment.
2.2. Court
2.2.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) The Court took the position that congresses right to regulate interstate commerce was expansive. While the goal of congress may have been to redress "moral wrongs", the vehicle they used was entirely within their authority. This expansive view of the commerce clause remains a lynchpin for a wide range of regulatory and procedural law.
2.2.2. Fifth Amendment, US Constitution The Court considered whether there was a legitimate interstate commerce interest served in congresses actions. In part because 75% of the motel's guests came from out of state, and because of its proximity to 2 major interstate highways, the Court held that there is a legitimate interstate commerce interest. As such, Congress is within its rights to regulate the business, and it does not constitute uncompensated seizure or a violation of due process.
2.2.3. Thirteenth Amendment, US Constitution The Court flatly rejected the Thirteenth Amendment claim as being without merit, as the Amendment was clearly not intended to restrain civil rights legislation.
2.3. Defendant
2.3.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) Because the hotel served interstate travelers, Congress has express authority to regulate under the authority granted in the Interstate Commerce Clause of the US Constitution.
2.3.2. Fifth Amendment, US Constitution The reasonable regulation of interstate travel and commerce is not prohibited by the Fifth Amendment. Furthermore, incidental harm suffered by businesses forced to comply with said regulation does not constitute seizing of property without compensation or the denial of due process.
2.3.3. Thirteenth Amendment, US Constitution The Thirteenth Amendment is intended to ban slavery and it's association harms. In no way was it intended to prevent the enforcement of anti-discrimination laws. Additionally, forcing businesses to comply with anti-discrimination laws does not constitute forced servitude.
3. Issue
3.1. Facts
3.1.1. Parties
3.1.1.1. Plaintiff The Heart of Atlanta Motel in Atlanta, Georgia. Owner: Moreton Rolleston,
3.1.1.2. Defendant The United States, Congress
3.1.2. Procedural History The Civil Rights Act of 1964 banned racial discrimination in public places. The act was enforced in part through Congress's powers over interstate commerce
3.1.3. What Happened The Motel had a policy of not serving African Americans.
3.2. Legal Questions
3.2.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) Does the Commerce Clause give Congress the power to enforce the Civil Rights Act's prohibition against discrimination in public accommodations? Does Congress have the authority use interstate commerce regulatory authority granted by the Constitution as a tool to enforce legislative mandates and prevent "moral wrongs"?
3.2.2. Thirteenth Amendment, US Constitution Does mandating compliance with procedural law and regulations for non-discrimination in public accommodations constitute the unlawful taking of private property or denial of due process of law?
3.2.3. Fifth Amendment, US Constitution Does mandating compliance with procedural law and regulations for non-discrimination in public accommodations constitute involuntary servitude?
4. Conclusions
4.1. Legal Determinations
4.1.1. Article I, Section 8, Clause 3:[3] US Constitution (Commerce Clause) The U.S. Supreme Court ruled that Congress was within its rights when it passed the Civil Rights Act and sought to enforce it through its authority under the Interstate Commerce Clause.
4.1.2. Fifth Amendment, US Constitution Because 75% of the hotel's customers came from other states, and because the hotel was located within close proximity to several highways and Interstates, the Court held that the business did impact interstate commerce and was subject to the authority of Congress under the Interstate Commerce Clause. As such, the hotel was required to accept guests without regard to race.
4.1.3. Thirteenth Amendment, US Constitution Because the Thirteenth Amendment was clearly intended to ban slavery and not to obstruct anti-discrimination laws, the court held the the Thirteenth Amendment claim was without merit.
4.2. Importance
4.2.1. This was the first significant test on the Civil Rights act. The subsequent ruling affirmed the legal basis of the dismanling of public segregation and Jim Crow policies. This case clearly established Congresses' power to enforce the Civil Rights Act though the power granted to it by the Commerce Clause of the US Constitution. It also affirmed Congress' legitimate role in enforcing a broad range interstate legislative mandates through the authority granted to it by the Commerce Clause.
4.3. Impact
4.3.1. Save Our Aquifer v. City of San Antonio, 237 F. Supp. 2d 721 (W.D. Tex. 2002) Voting right act enforcement
4.3.2. Willis v. Pickrick Restaurant, 231 F. Supp. 396 (N.D. Ga. 1964) Discrimination in Restaurant accomidations
4.4. Influence
4.4.1. While this case applied specifically to public accommodations, the broad interpretation of the commerce clause meant that many business practices could and likely would fall under the requirements of the Civil Right's Act and any future similar legislation. Modern non-discrimination policies are widespread and virtually universal. Examples include customer service, employment, and housing.