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Heart of Atlanta Motel, Inc. v. US

(1964)

Supreme Court of the United States - 379 U.S. 241

tl;dr:

Congress can regulate local activities to combat racial discrimination.

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ICRAIssue, Conclusion, Rule, Analysis for Heart of Atlanta Motel, Inc. v. US

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Facts & HoldingHeart of Atlanta Motel, Inc. v. US case brief 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 | Case Brief DeepDive
Majority opinion, author: Mr. Justice Clark
Level 1
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This legal case upholds the constitutionality of Title II of the Civil Rights Act of 1964, which prohibits discrimination in public accommodations based on race, color, religion, or national origin. The Supreme Court ruled that Congress had the power to pass the Act under the Commerce Clause of the Constitution. The Act applies to motels serving interstate travelers, and Congress acted within its power in adopting the Act. The means chosen by Congress to eliminate obstructions caused by racial discrimination in interstate commerce must be reasonably adapted to the end permitted by the Constitution. The procedures for enforcing Title II include civil actions initiated by individuals and complaints filed by the Attorney General in district court for patterns or practices of resistance to the Act. Private clubs or establishments not open to the public are exempt from the Act, except for their facilities made available to customers of a covered establishment. The remedies provided in the Civil Rights Act are the only way to enforce the rights granted by the Act, but individuals or state/local agencies can still assert their rights under other federal or state laws that are not inconsistent with the Act and pursue any civil or criminal remedy available to enforce their rights.

Opinion (Concurrence), author: Mr. Justice Black
Level 1
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The Heart of Atlanta Motel and Ollie's Barbecue are appealing court orders to stop discriminating against African American guests. The court upheld the application of Title II of the Civil Rights Act of 1964 to both establishments, stating that Congress has the power to regulate commerce among states and can expand its power to regulate local entities if their activities burden interstate commerce. The Civil Rights Act of 1964 is a valid exercise of congressional power because the discriminatory practices of the motel and restaurant directly interfered with interstate travel and could distort or impede interstate trade. The Supreme Court has consistently upheld Congress's power to protect interstate commerce from activities that would otherwise be beyond its regulatory authority.

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Opinion (Concurrence), author: Mr. Justice Douglas
Level 1
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The Civil Rights Act is a valid means of enforcing Fourteenth Amendment rights and protecting interstate commerce, according to Justice Douglas. Section 201(a) of the Act guarantees equal access to public accommodations without discrimination based on race, color, religion, or national origin, which is covered by the Equal Protection Clause of the Fourteenth Amendment. Section 201(d) defines "state action" under the Fourteenth Amendment, including discrimination or segregation carried out under color of law, custom, or action of the state or political subdivision. The Commerce Clause is relevant to some definitions of "place of public accommodation" in the Act, but not the only basis for inclusion. Private property owners who offer goods or services to the public cannot refuse service based on race, religion, or national origin. The Administration Bill (H.R. 7152) acknowledged discrimination in public accommodations through the invocation of Fourteenth Amendment powers and the Commerce Clause. The Committee Bill contained the present §§ 201 (d) and 202, but with an even broader definition of "state action" in § 201 (d) than the current version. The Attorney General did not realize that these additions limited the Fourteenth Amendment foundation of the bill to the additions alone, while the commerce language sections were still supported by the Fourteenth Amendment in the alternative.

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Opinion (Concurrence), author: Mr, Justice Goldberg
Level 1
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The Civil Rights Act of 1964 is a valid exercise of Congress' power under the Commerce Clause and Section 5 of the Fourteenth Amendment. Its primary purpose is to protect human dignity by prohibiting discrimination in public accommodations that affect commerce. Congress has the authority to implement the rights protected by Section 1 of the Fourteenth Amendment through the Commerce Clause and Section 5. The Act provides guidelines for practical administration and distinguishes between public and private accommodations. The Court need not consider whether the Act is also supported by Congress' power under Section 5 of the Fourteenth Amendment.

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