Heart of Atlanta Motel, Inc. V United States (1964)

Get Started. It's Free
or sign up with your email address
Rocket clouds
Heart of Atlanta Motel, Inc. V United States (1964) by Mind Map: Heart of Atlanta Motel, Inc. V United States (1964)

1. Facts

1.1. Parties

1.1.1. Heart of Atlanta Motel

1.1.2. United State of America

1.2. What Happened

1.2.1. Heart of Atlanta Motel is a 216 room motel located at the intersection of two interstates in Atlanta, Georgia

1.2.2. Heart of Atlanta Motel hosts mostly out of state guests

1.2.3. Heart of Atlanta Motel would like to continue to exclude black Americans from staying there

1.2.3.1. Heart of Atlanta has a no black Americans policy and would like to continue this policy

1.2.4. Heart of Atlanta Motel sued the United State of America to find the Civil Rights Act of 1964 unconstitutional as exceeding the Commerce Clause

1.3. Procedural History

1.3.1. The case was initially tried in the Northern District Court of Georgia in 1964 the Court ruled against Heart of Atlanta Motel

1.3.1.1. The lower court held Title II of the Civil Rights Act of 1964 as constitutional

1.3.1.2. The lower court issued a permanent injunction requiring the Heart of Atlanta Motel to refrain from racial discrimination

1.3.2. Heart of Atlanta Motel appealed, and the Supreme Court of the United States decided to hear the case without it proceeding through the 11th Circuit.

2. Issue Before the Court

2.1. Whether congress exceeded its Commerce Clause power by depriving motel the right to choose its customers

3. Rule of Law

3.1. Congress can regulate local activities that substantially affect interstate commerce

3.1.1. Means of regulation are okay as long as the end is constitutional

3.1.1.1. Plaintiff must show that the requirements of Civil Rights Act of 1964 exceeded the authority granted to congress over interstate commerce

3.2. 5th Amendment

3.2.1. Plaintiff must show that the Civil Rights Act of 1964 violated its 5th amendment and resulted in unjust deprivation of its property

4. Application

4.1. The US argues that congress did not unconstitutionally exceed its powers under the Commerce Clause by enacting Title II of the 1964 Civil Rights Act, which prohibited racial discrimination in public accommodations.

4.1.1. The court observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75 and 85 as well as two major Georgia highways, the Court found that the business clearly affected interstate commerce.

4.1.1.1. The U.S. Supreme Court held that Congress acted well within its authority under the Commerce Clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question.

4.1.1.1.1. Congress was within its authority because Courts gave broad deference to congress on commerce clause issues that involved free movement of people

4.2. The plaintiff has the burden of proving...

4.2.1. The court was not within its authority under the Commerce Clause to pass the Civil Rights Act of 1964

4.2.1.1. In fact, the court exceeded its authority in passing this law

4.2.2. Its 5th amendment rights were violated and this impacted the use of property and compensation

5. Conclusion

5.1. The US Supreme Court upheld the permanent injunction issued by the district court

5.1.1. This prevented Heart of Atlanta from discriminating against patrons based on race

6. Impact

6.1. US v Alfonso LOPEZ,Jr (1995)

6.1.1. Alfonso Lopez brought a gun to school and was convicted of violating the Gun Free School Zones Act of 1990

6.1.1.1. The trial court found the defendant guilty. He appealed and the court of appeals had to decide whether congress exceeded its Commerce Cause power by extending it to activities that don't have an apparent connection to interstate commerce

6.1.1.1.1. The Supreme Court held the court of appeals decisions that the possession of a hangun near school is not an activity that has a substantial effect on interstate commerce.

6.2. US v Jean MARTIGNON (2004)

6.2.1. Jean Martignon operated Midnight Records and was indicted by a federal grand jury for selling unauthorized recordings of live performances

6.2.1.1. Jean Martignon moved to dismiss the Indictment on the basis that the anti-bootlegging statute is unconstitutional because it was to broad and did not limit the statutes reach.

6.2.1.1.1. The government cited many past cases including Heart of Atlanta Motel, Inc. v United States and Congress's ability to enact legislation under its Commerce Clause but the court agreed it was too broad.

7. Importance

7.1. A healthcare professional would care about the situation because 1) they would need to treat all admitted, without discriminating on race 2) and in their personal life, if they were a minority they need not worry about being discriminated against in hotels

7.1.1. On the other hand, a concern a healthcare worker could have is if they treat traveling clients, or have traveling nurses, Congress could greatly impact their organization with new laws by utilizing their Commerce Clause power

8. Influence

8.1. Sexual Orientation Discrimination

8.1.1. "Deprivation of personal dignity that surely accompanies denials of equal access to public establishments,” Heart of Atlanta Motel, Inc. v. United States, means that an antidiscrimination law fulfills its purpose when it reaches all, not simply most, public accommodations

8.1.1.1. Telescope Media Group v. Lindsey (2017)

8.2. ADA Compliance

8.2.1. The Supreme Court upheld the constitutionality of the public accommodations provisions of the Civil Rights Act of 1964 in Heart of Atlanta Motel, Inc. v. United States. The Supreme Court agreed that Congress possessed the authority to outlaw discrimination in public accommodations on the basis of race. Heart of Atlanta Motel, Inc., Congress acted again to outlaw discrimination in public accommodation.

8.2.1.1. Civil Rights Education and Enforcement Center v Hospitality Properties Trust (2017)