Heartland of Atlanta Motel v. United States 379 U.S. 241 (1964)

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Heartland of Atlanta Motel v. United States 379 U.S. 241 (1964) by Mind Map: Heartland of Atlanta Motel v. United States 379 U.S. 241 (1964)

1. Facts

1.1. Parties

1.1.1. Heart of Atlanta Motel

1.1.2. The United States of America

1.2. What Happened

1.2.1. The owner of the Heart of Atlanta motel refused to rent rooms to African Americans. The owner was concerned that he would be forced to rent his room to African Americans against his wishes.

1.3. Procedural History

1.3.1. A three-judge trial in the US District Court for the Northern District of Georgia ruled in favor of the Act and filed an injunction against the plaintiff, forcing immediate ceasing of discrimination based upon race. The plaintiff appealed this decision the the US Supreme Court

2. Issue Before the Court

2.1. "(1) Whether Congress had a rational basis for finding that racial discrimination by motels affected commerce, and (2) if it had such a basis, whether the means it selected to eliminate that evil are reasonable and appropriate." (Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 258, 85 S. Ct. 348, 358, 13 L. Ed. 2d 258 (1964))

3. Rule of Law

3.1. Congressional authority

3.1.1. Article I, Section 8, of the US Constitution (referred to as the commerce clause) gives Congress the ability to regulate interstate commerce

3.2. Precedence

3.2.1. Gibbons v Ogden expanded the commerce clause to give the federal government the ability to regulate intrastate commerce so long as the trade "substantially affected" the commerce in more than one state.

3.2.2. Wickard v Filburn found that a farmer's wheat harvest can be regulated by the federal government despite the intention for self-use of the crop. The finding was based upon a set amount of acreage and bushels of wheat as allotted for by the Agricultural Adjustment Act of 1938. Wheat production was determined to affect interstate commerce as the flow can can result in shortages or surpluses that have subsequent effects on pricing.

4. Application

4.1. The owner felt that his motel was "of a purely local character" with no bearing on interstate commerce.

4.1.1. As such, the owner felt that his business was not subject to the Civil Rights Act of 1964. The owner claimed that the Civil Rights Act of 1964 was unconstitutional, as it was believed that the US Congress had overstepped its authority to regulate commerce. The owner (plaintiff) sought an injunction against the Attorney General to prevent him from enforcing the act, thereby allowing the discriminatory behavior to continue.

4.2. Defendant argued that hotels/motels do have a bearing on interstate commerce.

4.2.1. As such, Congress does have the ability to apply regulation and laws to the industry. Defendents counterclaimed to have the Civil Rights Act of 1964 enforced thereby preventing the hotel owner to decline room bookings based on a prohibited basis.

4.3. Plaintiff has burden of proving that Congress has exceeded its authority in the application of federal laws to the local business

5. Conclusion

5.1. The US Supreme Court ruled in favore of the United States, upholding the ruling and injunction filed by the US District Court.