1. Believes congress exceeded its authority to regulate commerce in the act under Article 1, subsection8 clause 3 of the Constitution
2. Facts
2.1. Heart of Atlanta Motel restricts renting of rooms to only white customers; Restaurant restrict dining to white customers.
2.1.1. 3/4 of motel customers are from out of state; Restaurant clientele is more local
2.1.2. Motel and Restaurant are located in Georgia; 216 rooms; readily accessible to interstate system
2.1.3. Appellant advertises in national publications and local road signage
2.2. Civil Rights Act of 1964 says this is illegal and the US sued Heart of Atlanta to change their illegal practices.
2.3. The District Court for the Northern District of Georgia upheld the Act as constitutional and Heart of Atlanta appealed.
3. Issue
3.1. Did the District Court properly uphold the constitutionality of Title II of the Civil Rights Act of 1964? Can the Federal Government tell a business who it must serve or is it a violation of constitutional rights?
4. Rule of Law
4.1. The overarching law being reviewed in this case is the Civil Rights Act of 1964 - however that is being challenged on its constitutionality based on the following factors by the Defendant/Appellant.
4.1.1. US Constitution Article 1 subsection 8 clause 3
4.1.2. 5th Amendment
4.1.3. 13th Amendment
5. Analysis
5.1. Plaintiff/Appellee
5.1.1. African Americans being unable to find accommodation "interferes significantly" with interstate commerce
5.1.1.1. Commerce Clause grants the right to remove such obstructions
5.1.2. Fifth Amendment does not prohibit regulation and that regulation does not rise to "taking" as it is understood to be defined
5.1.3. The the 13th Amendment claim is nonsense as it was created to abolish slavery not protect discrimination.
5.1.3.1. This doesn't create "servitude" for the Appellant.
5.2. Defendant/Appellant
5.2.1. Placing them in involuntary servitude violating the 13th Amendment
5.3. They are being deprived their right to select their customers taking of their rights without due process or compensation violating 5th Amendment
5.4. District Court for the Northern District of Georgia
5.4.1. The court said that while the commerce approach is one of policy that Congress can select, as is not for the court to dictate, there is a question of human dignity here beyond commerce
5.4.1.1. Title II of the Civil Rights Act of 1964 banning discrimination in accommodations is not a violation of Fifth Amendment and deprivation of property/liberty without due process.
5.4.1.2. Neither does it violate the 13th Amendment around involuntary servitude.
5.4.1.3. Title II of the Civil Rights Act of 1964 is valid use of Congressional power/oversight
5.4.1.3.1. Interstate Commerce because majority of customers are from more than just state of Georgia
5.4.1.3.2. Protection of interstate commerce is regulated by Congress under the Commerce Clause
5.4.1.3.3. Just because their is also a moral component doesn't invalidate the Commerce Clause basis
5.4.1.3.4. This still applies even if the business is "local" as Congress still has the right to enforce upon "local" businesses conducting interstate commerce
6. Impact
6.1. Masterpiece Cakeshop, Ltd. v. Colo. Civil Rights Comm'n
6.1.1. This was a case where a bakery was sued for not making wedding cakes for same sex couples.
6.1.2. While Heart of Atlanta was cited here by the Colorado Civil Rights Commission the Court disagreed and said that was not the question in this case which was not about commerce but about freedom of speech/protected speech.
6.2. United States v. Guest
6.2.1. This case involved the killing of an African American man while traveling on a public road by a group of white men. His killers were tried and acquitted by an all-white jury.
6.2.2. The court overturned the acquittal on the basis that the 14th Amendment provides equal protections which were not provided by the police who accepted false testimony in a racially motivated conspiracy.
7. Importance
7.1. Clear case law showing that suits showing discrimination of protected classes (expanded beyond just race) will be upheld by the courts and can force business changes/penalties.
7.2. Federal regulations supersede local and state laws when activities are deemed part of interstate commerce. Therefore a change in local law may not have an impact on business practices.
8. Influence
8.1. Treatment of public lodging customers based on protected class (Race/Color in this case). The interesting component here is for the future broader impact based on sexual preference, religion, disability etc
8.2. Treatment of dining customers based on protected class (race/color in this particular case). The interesting component here is for the future broader impact based on sexual preference, religion, disability etc
8.3. What other activities based on interstate commerce might be impacted? 3rd party Fulfillment Services? Group Travel Bookings?
9. Conclusion
9.1. The court upheld the lower court ruling in that the Civil Rights Act of 1964 is constitutional in its regulation of interstate commerce.
9.1.1. This may or may not have an impact on individual businesses incomes/viabilities but that is not the concern of the court
9.1.2. This ruling impacts 20,000,000 African Americans who can and may choose to travel between states - in aggregate this significantly impacts interstate commerce and protected citizen populations
9.1.3. Nothing in the Civil Rights Cases, 109 U.S. 3 which invalidated the Civil Rights Act of 1875 implies congress is without the power to use Commerce Clause in such away. Appears to be adding more support to the decision.