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Heart of Atlanta Motel, Inc. v. US

379 U.S. 241 (1964)

tl;dr: Congress can regulate local activities to combat racial discrimination.

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The Heart of Atlanta Motel violated the Civil Rights Act of 1964 by refusing to rent rooms to Black guests. The District Court issued a permanent injunction against the motel, upholding the Act's validity. The Act prohibits discrimination in public accommodations based on race, color, religion, or national origin, including inns, hotels, motels, restaurants, and motion picture houses. Private clubs are excepted under certain conditions. The Act is considered constitutional under the Commerce Clause, as discrimination by hotels and motels impedes interstate travel. The lower court did not err in issuing the permanent injunction. Section 202 prohibits discrimination or segregation on the basis of race, color, religion, or national origin, even if required by state law. Section 203 provides remedies for violations through civil actions for preventive relief, and the Attorney General may bring suit against any person or group engaged in a pattern or practice of resistance to the full enjoyment of the rights secured by this title. The case establishes that Congress can regulate local actions that impact interstate commerce, including prohibiting motels from discriminating based on race. The Civil Rights Act's prohibition of racial discrimination by motels is a reasonable means to eliminate harm to interstate commerce and does not violate the Fifth Amendment's protection of liberty or property. Title II of the Act, which ensures equal enjoyment of public accommodations without discrimination, is affirmed. Civil action can be taken for violations, and attorney's fees may be awarded to the prevailing party. The court may refer the matter to the Community Relations Service to attempt to obtain voluntary compliance.

The Civil Rights Act of 1964 prohibits discrimination at any establishment and aligns with the Fourteenth Amendment. Congress used its power under the Commerce Clause and § 5 of the Fourteenth Amendment to regulate racial segregation in the Act. Discriminatory practices can burden interstate commerce and discourage travel. The anti-racial-discrimination provisions of Title II of the Civil Rights Act of 1964 are valid as applied to motels and restaurants that discriminate against customers, as their practices directly interfere with interstate travel and could impede interstate trade. The Act is valid as applied to establishments whose operations affect interstate commerce or whose discrimination is supported by state action. The Thirteenth Amendment is additional authority for the legislation. The Senate's understanding was likely the same as the House's view.

Justice Goldberg confirms that the Civil Rights Act of 1964 is constitutional, citing the Commerce Clause and Section 5 of the Fourteenth Amendment. The Act upholds equal treatment and human dignity in public accommodations, which aligns with Bell v. Maryland.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:A motel in downtown Atlanta wanted to continue a practice...

Holding:Discrimination by race places a heavy burdens on interstate commerce. Additionally,...

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Heart of Atlanta Motel, Inc. v. US

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