1. Influences
1.1. Businesses cannot discriminate against patrons due to sexual orientation if a similar case can be made for upholding the interests of interstate commerce
1.2. The Commerce Clause has been broadly used as justification for various types of Federal laws banning discriminatory behaviors by individuals and corporations. The most important aspect of this concept is that there must be a compelling interest to protect interstate commerce for laws to be enacted with this justification
2. Rule of Law
2.1. The United States government has the right to regulate interstate commerce and the discrimination of race for hotel use infringes on citizen's ability to travel freely and engage in interstate commerce
3. Issue Before the Court
3.1. Whether the United States government has the right to compel businesses to comply with the Civil Rights Act of 1964 on the basis of regulating interstate commerce
4. Facts
4.1. Parties
4.1.1. Appellant: Heart of Atlanta Hotel, Inc
4.1.2. Appellee: United States of America
4.2. What happened
4.2.1. 7/2/1964: Civil Rights Act of 1964 signedinto law by President Johnson
4.2.1.1. Outlaws discrimination based on race, color, religion, sex or national origin
4.2.1.2. Congress asserted right to enact law based on right to regulate interstate commerce (Constitution, Article 1) and equal protections clause (Fourteenth Amendment)
4.2.1.3. Law immediately challenged in courts on numerous fronts
4.2.2. Heart of Atlanta Hotel, Inc operated a 216-room motel in Atlanta, Georgia. They motel was near interstate highways with a majority of guests from out-of-state
4.2.2.1. Hotel did not allow African American patrons to stay at the motel
4.3. Procedural history
4.3.1. Case initially filed in the United States District Court for the Northern District of Georgia, Atlanta division
4.3.1.1. Court affirmed the power of the United States government to require the Heart of Atlanta Hotal, Inc to not discriminate upon the basis of race according to the Civil Rights Act of 1964
4.3.1.2. Appellant filed a permanent injunction against the Civil Rights Act of 1964, declaring the Act unconstitutional
4.3.2. Heart of Atlanta Hotel, Inc. appealed to the Supreme Court
5. Analysis/Application
5.1. Application
5.1.1. Appellant argued that the inability to discriminate based on race:
5.1.1.1. Is not valid since his establishment does not infringe upon a person's ability to engage in interstate commerce (Constitution, Commerce Clause)
5.1.1.2. In not valid since people are not the basis of commerce; the Hotel does not profit from the sale of goods, but rather people staying in their rooms (Constitution, Commerce Clause)
5.1.1.3. Deprives him of his property without due process since he cannot rent his rooms as he chooses, thus violating the Fifth Amendment
5.1.1.4. Forces him into involuntary servitude thus violating the Thirteenth Amendment
5.1.2. Appellee argued that the United States government had jurisdiction to compel Heart of Atlanta Hotel, Inc. to not discriminate based on race:
5.1.2.1. The Hotel does engage in interstate commerce because it is located close to several interstate highways and 75% of its guests come from out-of-state
5.1.2.2. Congress has a compelling interest to regulate interstate commerce and discrimination based on race prevents the free exchange of commerce (Constitution, Commerce Clause) both for the individual who cannot obtain lodging and for nearby businesses that will also be discriminated against because other businesses will not interact in the vicinity
5.1.2.3. The Act does not deprive the Hotel of it's property under the Fifth Amendment as the Hotel does not have the right to decide who it accepts as guests entirely free from government regulation
5.1.2.4. The Act does not compel the Hotel to act involuntarily as common-law innkeeper rules which predate the Thirteenth Amendment also do not allow for deprivation of accommodations for non-material reasons
5.1.3. The Court broadly agreed with the Appellee's argument; however, the Court did acknowledge that Congress could have specifically addressed the issue of discrimination of this nature with legislation
5.2. Conclusion
5.2.1. Circuit Court ruling upheld unanimously
5.3. Impact
5.3.1. Adarand Contractors V. Pena (1974): The Supreme Court struck down a law preferentially awarding a contract due to minority status of the contractor. The case referenced a compelling interest in upholding the interests of interstate commerce
5.3.2. United States v. Lopez (1995): The Court asserted that Congress had exceeded its powers by legislating the Guns Free School Zones Act. Congress had cited the Commerce Clause to restrict allowing guns into school zones. The Court stated that this restriction did not influence interstate commerce and therefore was therefore not a relevant justification for restricting gun access (Second Amendment).
5.4. Importance
5.4.1. Race is not a valid rationale to deny interstate travelers the right to stay at a hotel. The basis of this argument is found in the compelling interests of the federal government to protect the interests of interstate commerce. The ruling has been more broadly applied to other kinds of business interactions in which race could be used to justify a denial of services.