Heart of Atlanta Motel vs United States

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Heart of Atlanta Motel vs United States by Mind Map: Heart of Atlanta Motel vs United States

1. "Application of Title II to Heart of Atlanta Motel: It is admitted that the operation of the motel brings it within the provisions of 201(a) of the Act, and that appellant refused to provide lodging for transient Negroes because of their race or color, and that it intends to continue that policy unless restrained. The sole question posed is, therefore, the constitutionality of the Civil Rights Act of 1964 as applied to these facts. The legislative history of the Act indicates that Congress based the Act on 5 and the Equal Protection Clause of the Fourteenth Amendment, as well as its power to regulate interstate commerce under Art. I, 8, cl. 3, of the Constitution. The Senate Commerce Committee made it quite clear that the fundamental object of Title II was to vindicate 'the deprivation of personal dignity that surely accompanies denials of equal access to public establishments.' At the same time, however, it noted that such an objective has been and could be readily achieved 'by congressional action based on the commerce power of the Constitution.' S.Rep. No. 872, supra, at 16-17. Our study of the legislative record, made in the light of prior cases, has brought us to the conclusion that Congress possessed ample power in this regard, and we have therefore not considered the other grounds relied upon. This is not to say that the remaining authority upon which it acted was not adequate, a question upon which we do not pass, but merely that, since the commerce power is sufficient for our decision here, we have considered it alone. Nor is 201(d) or 202, having to do with state action, involved here. and we do not pass upon either of those sections. 5. The Civil Rights Cases, 109 U. S. 3 (1883), and their Application. In light of our ground for decision, it might be well at the outset to discuss the Civil Rights Cases, supra, which declared provisions of the Civil Rights Act of 1875 unconstitutional. 18 Stat. 335, 336. We think that decision inapposite and without precedential value in determining the constitutionality of the present Act. Unlike Title II of the present legislation, the 1875 Act broadly proscribed discrimination in "'nns, public conveyances on land or water, theaters, and other places of public amusement,' without limiting the categories of affected businesses to those impinging upon interstate commerce. In contrast, the applicability of Title II is carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people, except where state action is involved. Further, the fact that certain kinds of businesses may not in 1875 have been sufficiently involved in interstate commerce to warrant bringing them within the ambit of the commerce power is not necessarily dispositive of the same question today. Our populace had not reached its present mobility, nor were facilities, goods and services circulating as readily in interstate commerce as they are today. Although the principles which we apply today are those first formulated by Chief Justice Marshall in Gibbons v. Ogden, 9 Wheat. 1 (1824), the conditions of transportation and commerce have changed dramatically, and we must apply those principles to the present state of commerce. The sheer increase in volume of interstate traffic alone would give discriminatory practices which inhibit travel a far larger impact upon the Nation's commerce than such practices had on the economy of another day. Finally, there is language in the Civil Rights Cases which indicates that the Court did not fully consider whether the 1875 Act could be sustained as an exercise of the commerce power. Though the Court observed that 'no one will contend that the power to pass it was contained in the Constitution before the adoption of the last three amendments [Thirteenth, Fourteenth, and Fifteenth],' the Court went on specifically to note that the Act was not 'conceived' in terms of the commerce power, and expressly pointed out: 'Of course, these remarks [as to lack of congressional power] do not apply to those cases in which Congress is clothed with direct and plenary powers of legislation over the whole subject, accompanied with an express or implied denial of such power to the States, as in the regulation of commerce with foreign nations, among the several States, and with the Indian tribes. . . . In these cases, Congress has power to pass laws for regulating the subjects specified in every detail, and the conduct and transactions of individuals in respect thereof.' At 18 [argument of counsel omitted from electronic version]. Since the commerce power was not relied on by the Government and was without support in the record, it is understandable that the Court narrowed its inquiry and excluded the Commerce Clause as a possible source of power. In any event, it is clear that such a limitation renders the opinion devoid of authority for the proposition that the Commerce Clause gives no power to Congress to regulate discriminatory practices now found substantially to affect interstate commerce. We therefore conclude that the Civil Rights Cases have no relevance to the basis of decision here, where the Act explicitly relies upon the commerce power and where the record is filled with testimony of obstructions and restraints resulting from the discriminations found to be existing." Justia Law

2. Facts

2.1. Parties: Heart of Atlanta Motel, Inc. (Plaintiff) vs United States (Defendant) U.S. Supreme Court (1964)

2.2. What Happened: "Appellant, the owner of a large motel in Atlanta, Georgia, which restricts its clientele to white persons, three-fourths of whom are transient interstate travelers, sued for declaratory relief and to enjoin enforcement of the Civil Rights Act of 1964, contending that the prohibition of racial discrimination in places of public accommodation affecting commerce exceeded Congress' powers under the Commerce Clause and violated other parts of the Constitution. A three-judge District Court upheld the constitutionality of Title II, 201(a), (b)(1) and (c)(1), the provisions attacked, and, on appellees' counterclaim, permanently enjoined appellant from refusing to accommodate Negro guests for racial reasons. The appellant contends that Congress, in passing this Act, exceeded its power to regulate commerce under Art. I, 8, cl. 3, of the Constitution of the United States; that the Act violates the Fifth Amendment because appellant is deprived of the right to choose its customers and operate its business as it wishes, resulting in a taking of its liberty and property without due process of law and a taking of its property without just compensation; and, finally, that, by requiring appellant to rent available rooms to Negroes against its will, Congress is subjecting it to involuntary servitude in contravention of the Thirteenth Amendment. The appellees counter that the unavailability to Negroes of adequate accommodations interferes significantly with interstate travel, and that Congress, under the Commerce Clause, has power to remove such obstructions and restraints; that the Fifth Amendment does not forbid reasonable regulation, and that consequential damage does not constitute a 'taking' within the meaning of that amendment; that the Thirteenth Amendment claim fails because it is entirely frivolous to say that an amendment directed to the abolition of human bondage and the removal of widespread disabilities associated with slavery places discrimination in public accommodations beyond the reach of both federal and state law. At the trial, the appellant offered no evidence, submitting the case on the pleadings, admissions and stipulation of facts; however, appellees proved the refusal of the motel to accept Negro transients after the passage of the Act. The District Court sustained the constitutionality of the sections of the Act under attack (201(a), (b)(1) and (c)(1)) and issued a permanent injunction on the counterclaim of the appellees. It restrained the appellant from '[r]efusing to accept Negroes as guests in the motel by reason of their race or color' and from '[m]aking any distinction whatever upon the basis of race or color in the availability of the goods, services, facilities. privileges, advantages or accommodations offered or made available to the guests of the motel, or to the general public, within or upon any of the premises of the Heart of Atlanta Motel, Inc.'" Justia Law

2.3. Procedural History: Procedural History: "Congress first evidenced its interest in civil rights legislation in the Civil Rights or Enforcement Act of April 9, 1866. There followed four Acts, with a fifth, the Civil Rights Act of March 1, 1875, culminating the series. In 1883, this Court struck down the public accommodations sections of the 1875 Act in the Civil Rights Cases, 109 U. S. 3. No major legislation in this field had been enacted by Congress for 82 years when the Civil Rights Act of 1957 became law. It was followed by the Civil Rights Act of 1960. Three years later, on June 19, 1963, the late President Kennedy called for civil rights legislation in a message to Congress to which he attached a proposed bill. Its stated purpose was "to promote the general welfare by eliminating discrimination based on race, color, religion, or national origin in . . . public accommodations through the exercise by Congress of the powers conferred upon it . . . to enforce the provisions of the fourteenth and fifteenth amendments to regulate commerce among the several States, and to make laws necessary and proper to execute the powers conferred upon it by the Constitution." Bills were introduced in each House of the Congress, embodying the President's suggestion, one in the Senate being S. 1732 and one in the House H.R. 7152. However, it was not until July 2, 1964, upon the recommendation of President Johnson, that the Civil Rights Act of 1964, here under attack, was finally passed. After extended hearings, each of these bills was favorably reported to its respective house, H.R. 7152 on November 20, 1963, H.R.Rep. No. 914, 88th Cong., 1st Sess., and S. 1732 on February 10, 1964, S.Rep. No. 872, 88th Cong., 2d Sess. Although each bill originally incorporated extensive findings of fact, these were eliminated from the bills as they were reported. The House passed its bill in January, 1964, and sent it to the Senate. Through a bipartisan coalition of Senators Humphrey and Dirksen, together with other Senators, a substitute was worked out in informal conferences. This substitute was adopted by the Senate and sent to the House, where it was adopted without change. This expedited procedure prevented the usual report on the substitute bill in the Senate as well as a Conference Committee report ordinarily filed in such matters. Our only frame of reference as to the legislative history of the Act is, therefore, the hearings, reports and debates on the respective bills in each house. The Act as finally adopted was most comprehensive, undertaking to prevent, through peaceful and voluntary settlement, discrimination in voting as well as in places of accommodation and public facilities, federally secured programs, and in employment. Since Title II is the only portion under attack here, we confine our consideration to those public accommodation provisions." Justia Law

3. Issue

3.1. "This is a declaratory judgment action, 28 U.S.C. 2201 and 2202 (1958 ed.), attacking the constitutionality of Title II of the Civil Rights Act of 1964, 78 Stat." Justia Law

4. Rule of Law

4.1. "Title II of the Act. This Title is divided into seven sections, beginning with 201(a), which provides that: All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation, as defined in this section, without discrimination or segregation on the ground of race, color, religion, or national origin.' There are listed in 201(b) four classes of business establishments, each of which 'serves the public' and 'is a place of public accommodation' within the meaning of 201(a) 'if its operations affect commerce, or if discrimination or segregation by it is supported by State action.' The covered establishments are: '(1) any inn, hotel, motel, or other establishment which provides lodging to transient guests, other than an establishment located within a building which contains not more than five rooms for rent or hire and which is actually occupied by the proprietor of such establishment as his residence;' '(2) any restaurant, cafeteria . . . [not here involved];' '(3) any motion picture house . . . [not here involved];""(4) any establishment . . . which is physically located within the premises of any establishment otherwise covered by this subsection, or . . . within the premises of which is physically located any such covered establishment . . . [not here involved].' Section 201(c) defines the phrase 'affect commerce' as applied to the above establishments. It first declares that 'any inn, hotel, motel, or other establishment which provides lodging to transient guests' affects commerce per se. Restaurants, cafeterias, etc., in class two affect commerce only if they serve or offer to serve interstate travelers or if a substantial portion of the food which they serve or products which they sell have 'moved in commerce.' Motion picture houses and other places listed in class three affect commerce if they customarily present films, performances, etc., 'which move in commerce.' And the establishments listed in class four affect commerce if they are within, or include within their own premises, an establishment 'the operations of which affect commerce.' Private clubs are excepted under certain conditions. See 201(e). Section 201(d) declares that 'discrimination or segregation' is supported by state action when carried on under color of any law, statute, ordinance, regulation or any custom or usage required or enforced by officials of the State or any of its subdivisions. In addition, 202 affirmatively declares that all persons 'shall be entitled to be free, at any establishment or place, from discrimination or segregation of any kind on the ground of race, color, religion, or national origin, if such discrimination or segregation is or purports to be required by any law, statute, ordinance, regulation, rule, or order of a State or any agency or political subdivision thereof.' Finally, 203 prohibits the withholding or denial, etc., of any right or privilege secured by 201 and 202 or the intimidation, threatening or coercion of any person with the purpose of interfering with any such right or the punishing, etc., of any person for exercising or attempting to exercise any such right. The remaining sections of the Title are remedial ones for violations of any of the previous sections. Remedies are limited to civil actions for preventive relief. The Attorney General may bring suit where he has 'reasonable cause to believe that any person or group of persons is engaged in a pattern or practice of resistance to the full enjoyment of any of the rights secured by this title, and that the pattern or practice is of such a nature and is intended to deny the full exercise of the rights herein described. . . .' A person aggrieved may bring suit, in which the Attorney General may be permitted to intervene. Thirty days' written notice before filing any such action must be given to the appropriate authorities of a State or subdivision the law of which prohibits the act complained of and which has established an authority which may grant relief therefrom. 204(c). In States where such condition does not exist, the court, after a case is filed, may refer it to the Community Relations Service, which is established under Title X of the Act. 204(d). This Title establishes such service in the Department of Commerce, provides for a Director to be appointed by the President with the advice and consent of the Senate, and grants it certain powers, including the power to hold hearings, with reference to matters coming to its attention by reference from the court or between communities and persons involved in disputes arising under the Act. Justia Law

5. Analysis/Application

6. Concolusion

6.1. "Title II of the Civil Rights Act of 1964 is a valid exercise of Congress' power under the Commerce Clause as applied to a place of public accommodation serving interstate travelers. Civil Right Cases, 109 U. S. 3, distinguished. Pp. 379 U. S. 249-262. (a) The interstate movement of persons is 'commerce' which concerns more than one State. Pp. 379 U. S. 255-256. (b) The protection of interstate commerce is within the regulatory power of Congress under the Commerce Clause whether or not the transportation of persons between States is 'commercial.' P. 379 U. S. 256. (c) Congress' action in removing the disruptive effect which it found racial discrimination has on interstate travel is not invalidated because Congress was also legislating against what it considered to be moral wrongs. P. 379 U. S. 257. (d) Congress had power to enact appropriate legislation with regard to a place of public accommodation such as appellant's motel even if it is assumed to be of a purely 'local' character, as Congress' power over interstate commerce extends to the regulation of local incidents thereof which might have a substantial and harmful effect upon that commerce. P. 379 U. S. 258. (2) The prohibition in Title II of racial discrimination in public accommodations affecting commerce does not violate the Fifth Page 379 U. S. 242 Amendment as being a deprivation of property or liberty without due process of law. Pp. 379 U. S. 258-261. (3) Such prohibition does not violate he Thirteenth Amendment as being 'involuntary servitude. P. 379 U. S. 261. 231 F.Supp. 393, affirmed." Justia Law

7. Impact

7.1. "Katzenbach v. McClung, 379 U.S. 294 (1964), is a United States Supreme Court case in which the Court unanimously held that Congress acted within its power under the Commerce Clause of the United States Constitution in forbidding racial discrimination in restaurants as this was a burden to interstate commerce." Wikipedia

7.2. "Constantine v Imperial Hotels Ltd [1944] KB 693 is an English tort law and contract case, concerning the implied duty of an innkeeper to offer accommodation to a guest unless for just cause." Wikipedia

8. Importance

8.1. At a minimum, the case establishes a legal precedence within the United States judicial system and provides a legal perspective to business leaders that commercial service cannot be denied from any individual on the basis of race.

9. Influence

10. APA Citation

10.1. Justia Law. (2019). Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964). [Retrieved from : https://supreme.justia.com/cases/federal/us/379/241/ [Accessed 1 Apr. 2019].

10.2. Wikipedia contributors. (2019, February 11). Heart of Atlanta Motel, Inc. v. United States. In Wikipedia, The Free Encyclopedia. Retrieved 23:06, April 1, 2019, from https://en.wikipedia.org/w/index.php?title=Heart_of_Atlanta_Motel,_Inc._v._United_States&oldid=882752193