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. Facts

1.1. Parties

1.1.1. US Supreme Court

1.1.2. Heart of Atlanta Motel

1.2. What happened

1.2.1. In 1964 Congress passed the Civil Rights Act, which prohibited racial discrimination in any "place of public accommodation." This was defined to include motels/restaurants/ect that substantially affect interstate commerce.

1.2.2. The owner of the Heart of Atlanta hotel refused to rent rooms to African Americans. He brought action against the courts claiming the Civil Rights Act was unconstitutional, and that the government exceeded its consititutional authority to regulate commerce by enacting the Act.

1.2.3. The owner also claimed his hotel purely was for local use, even though a majority of his guests (75%) were from out of state and he advertised nationally.

1.3. Procedural History

1.3.1. The owner of the Heart of Atlanta Motel filed suit in the U.S. District Court for the Northern District of Georgia. He asked that the Civil Rights Act of 1964 be found unconstitutional, because Congress would be going beyond its powers of commerce if they prohibited racial discrimination in private spaces.

1.3.2. The U.S. District Court for the Northern District of Georgia upheld the constitutionality of Title II under the Civil Rights Act of 1964.

1.3.3. The owner of the hotel appealed the district court’s decision to the Supreme Court.

1.3.4. The Supreme Court upheld the lower court's decision.

2. Issue before the court

2.1. The issue was whether or not the powers giving to Congress under the Commerce Clause were enough to allow them to force private businesses to abide by Title II of the Civil Rights Act.

3. Rule of Law

3.1. Congress can use the Commerce Clause to mandate that businesses follow the Civil Rights Act of 1964.

3.1.1. The movement of people traveling between different states is considered "commerce."

3.1.2. Prohibiting African Americans from staying in the hotel could impact interstate commerce, which the government has a right to regulate through the Commerce Clause.

4. Analysis/Application

4.1. Plaintiff

4.1.1. The government was infringing upon the owner's 5th Amendment Rights, because he could not pick which customers to serve. He also stated that the Civil Rights Act banned discrimination in public places, and extending the reach to interstate commerce through the Commerce Clause was unjust.

4.2. Defendant

4.2.1. Forcing African Americans to find alternate arrangements would be causing them distress as they would need to travel farther unfairly. It would be unjust to prohibit lodging to one race. As the hotel's location is central to 2 major highways and 75% of the clientele consists of out of state guests, the court ruled that this was a case of interstate travel. Interstate commerce would be affected if African Americans were unable to stay at the hotel, and if word spread less people may travel to the area.

4.3. Court

4.3.1. The court ruled that years of previous ruling and application of the Commerce Clause carry out that discrimination based on race is prohibited in public businesses, and that it's within the Commerce Clause's authority.

4.3.2. The court found that denying business to African Americans would have an impact on interstate commerce which is to be regulated by Congress. The court noted that Congress had not violated the Fourteenth Amendment in enforcing this law. The court also determined that they had neither forced Rolleston into involuntary servitude or deprived him of property or liberty because he was still being financially compensated for his rooms.

5. Conclusion

5.1. The powers of the government under the Commerce Clause give the government the power to force private businesses to abide by the Civil Rights Act.

5.1.1. The Rule holds that the government has these rights, and in this case that discrimination would impact interstate commerce that the government has substantive interest and can step in.

5.1.2. Opinion was that the 14th Amendment may have been better justification than the Commerce Clause for this case.

6. Impact

6.1. United States Supreme Court KATZENBACH v. McCLUNG(1964) No. 543

6.1.1. An Alabama restaurant (Ollie’s Barbecue) refused to serve African-Americans in the dining area, and only allowed African-Americans to get food through take-out service. The restaurant owner sued to prevent enforcement of the Civil Rights Act on his restaurant. He said that his single restaurant did not impact interstate commerce. The court had ruled in his favor but the Supreme Court overturned it, stating that it was discriminatory, and subject to commerce power of Congress under the Civil Rights Act. The court argued that if more restaurants acted in this way, there would be significant impacts on interstate commerce.

6.2. United States v. Lopez

6.2.1. A high school senior in San Antonio, Texas carried a fully loaded concealed handgun into school one day. The United States Federal Government argued that the possession of a firearm on or within an educational facility would likely lead to a violent crime. They noted that a crime of this caliber would impact the condition of the school and the health and safety of the students. The government believed that the commerce clause should be upheld in this case.

7. Importance

7.1. The Heart of Atlanta case was a landmark case because it held that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title II of the Civil Rights Act of 1964 (which prohibits discrimination in public accommodations).

8. Influence

8.1. Prior to this case, businesses could choose to discriminate against potential customers based on race. This case made it so that private businesses were no longer allowed to discriminate in this way, and now businesses need to serve all customers regardless of race.

8.2. This case also set the precedent that the government could intervene in a case of racial discrimination. For businesses, this means that there are real legal consequences to discriminating via race.