1 gen 1964 anni - Heart of Atlanta Motel v. U.S.

Descrizione:

Congress has the power to prohibit racial discrimination in businesses involved in substantial interstate commerce.

Overview:
In December of 1964, the Supreme Court ruled that in passing Title II of the Civil Rights Act, Congress did not exceed their authority granted by the commerce clause, therefore declaring Title II constitutional. The Civil Rights Act of 1964 intended to end segregation and discrimination based on race, color, religion, sex, or ethnicity. Title II of the Civil Rights Acts prohibits segregation or discrimination in public accommodations that involves interstate commerce. The commerce clause authorizes Congress to regulate commerce, such as the purchase, sale or exchange of merchandise, and the transportation of people, money or goods across state lines.

History:
On July 2nd, 1964, President Lyndon B. Johnson signed the Civil Rights Act in hopes of ending segregation in public places and banning employment discrimination. This act was one of the greatest legislative achievements in Civil Rights history. However, even with these laws set in place, it did not stop all citizens from changing their views on people based on the color of their skin. In the 60’s, a large majority of business owners and employers were still not accepting of African Americans and other minorities and continued to deny services or separate clients based on people’s skin color.

Commerce
There has always been controversy of regulating the economy. One of the primary reasons for the Constitutional Convention involved the federal government’s lack of ability to regulate economy. States had almost exclusive authority to regulate commercial activity in which they raised enough revenue to pay off war debt but states heavily taxed commercial business and property, which stagnated economy. In states that Article I, Section 8: “Congress shall have the power… to regulate commerce with foreign Nations, and among the several States…” However, there were still unsolved issues when deciphering what is commerce and defining “among the States.”


Biography:

Facts: The Heart of Atlanta Motel included 216 rooms and was located near two major interstates, highways 75 and 85, with approximately 75% of their guests from out of the state. It was flaunted as one of the finest hotels between the northeast and southeast, and was advertised nationally through magazines, billboards, and highway signs. The motel owner continued to deny services to African Americans, in belief that Title II of the Civil Rights Act was unconstitutional, exceeding Congress’s authority to regulate interstate commerce. The Civil Rights Act of 1964 prohibited discrimination based on race in any public establishment, affecting interstate commerce. Title II of the Civil Rights Act prohibited segregation or discrimination in places of public accommodation that involved interstate commerce. He also claimed that Title II violated the Fifth Amendment because it stripped him of his right to choose his customers and the Thirteenth Amendment because he was forced to participate in involuntary servitude by having to rent out rooms to African Americans. The owners were sued for not abiding with Title II of the Civil Rights Act of 1964. The district court upheld that Title II of the Civil Rights was constitutional and ordered an injunction forcing the motel owner to not discriminate against African American customers. The case was appealed to the Supreme Court and argued on October 5th, 1964.
Issue: Does Congress possess the authority to prohibit racial discrimination in public accommodations under the Commerce Clause?
Rule: The Civil Rights Act of 1964 is constitutional because Congress has authority to prohibit racial discrimination under the Commerce Clause.
Analysis: The regulation of hotel industry is part of interstate commerce. Therefore, Congress does have the power to prohibit racial discrimination. Under the commerce clause, the government has the power to serve an injunction to the motel from discrimination on the basis of race.
Conclusion: On December 14th, 1964, in a unanimous decision, the court affirmed the districts holdings. Justice Clark delivered the opinion of the court and argued that the business of the motel clearly affects interstate commerce, therefore falling within the scope of congress regulation. He also stated that the petitioner’s (motel owner) claims that the Title violated the Fifth and Thirteenth amendment were imprudent.
Commerce includes transportation of people, regardless of whether a ticket was purchased or prior accommodations were planned. Gibbons v. Ogden, Passenger Cases. Interstate commerce was affected due to the motel being strategically located near two major interstates and 75% of its clientele coming from outside of the state. Racial discrimination in hotels against African Americans limits these individuals to traveling freely across state lines, directly impacting interstate commerce.

Related cases

Wickard v. Filburn 
Passenger Cases

Gibbons v. Ogden
Facts: New York granted exclusive license to operate steamboats on all waters within its jurisdiction. Gibbons and Ogden were former partners who operated ships between New York and New Jersey. Ogden purchased rights to operate in NY water and Gibbons held a federal permit to operate along the coast. The partnership dissolved and Gibbons entered New York waters whenever possible in violation of Ogden’s monopoly rights. Ogden convinced New York courts to enjoin Gibbons from entering state waters.
Issue: Does the federal permit granted to Gibbons supersede NY law which granted monopoly to Ogden?
Rule: The federal permit supersedes state law because Congress possesses authority over interstate commerce and navigation is considered commerce
Analysis: Commerce not only involves the shipment of goods but involves intercourse between states and nations. Therefore, navigation is implied in commerce.
Conclusion: Congressional authority over commerce extends between U.S. and foreign nations, and among the states.

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