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Katzenbach v. McClung

379 U.S. 294 (1964)

tl;dr: Congress may regulate a discriminatory restaurant under the commerce clause because Congress had a rational basis to believe that discrimination would affect interstate commerce.

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The legal case "Katzenbach, Acting Attorney General, et al. v. McClung et al." involves a complaint against appellants who challenged the constitutionality of the Civil Rights Act of 1964 as applied to a restaurant. The District Court issued an injunction restraining appellants from enforcing the Act against the restaurant, but the judgment was reversed on direct appeal. The appellants moved to dismiss the complaint for lack of equity jurisdiction, arguing that the Civil Rights Act of 1964 only authorizes preventive relief and that there has been no threat of enforcement against the appellees. However, the Court considers the complaint as an application for a declaratory judgment under 28 U.S.C. §§ 2201 and 2202. Although declaratory relief is permitted under Rule 57 of the Federal Rules of Civil Procedure, it should not be granted where a special statutory proceeding has been provided, as is the case with Title II of the Civil Rights Act. Therefore, courts should ordinarily refrain from exercising their jurisdiction in such cases. The case involves a constitutional question regarding the Civil Rights Act of 1964, which has arisen in both this case and the companion case of Heart of Atlanta Motel. The court has decided to allow declaratory relief in this case due to the urgency of announcing a decision on the constitutionality of the Act. The case involves Ollie's Barbecue, a family-owned restaurant in Birmingham, Alabama, with a seating capacity of 220 customers and a take-out service for African Americans. The restaurant employs 36 people, two-thirds of whom are African American, and caters to a family and white-collar trade. The lower court erred in granting the injunction, and the Court has allowed declaratory relief in this case.

The case involves a restaurant called Ollie's Barbecue that has a history of racial discrimination and has been violating the Civil Rights Act since 1964. The focus is on whether Title II, which applies to restaurants like Ollie's Barbecue that receive around $70,000 worth of food that has moved in commerce annually, is a valid exercise of Congress's power. The lower court concluded that serving African Americans would result in significant business loss for the restaurant and that intrastate activities could only be regulated to the extent necessary for regulating interstate commerce. The government argues that Congress had ample reason to believe that racial discrimination in such restaurants creates commercial burdens on interstate commerce. The court erred in concluding that there was no connection between discrimination and the movement of interstate commerce, as there was testimony to support such a conclusion.

The passage discusses Congress's authority to regulate commerce between states, which includes regulating intrastate activities that impact interstate commerce. The National Labor Relations Act and past cases have established that this power extends to retail establishments like restaurants that obstruct or burden interstate commerce. Defendants challenge the idea that all restaurants meeting specific criteria affect commerce and object to the absence of a provision for a case-by-case assessment of whether racial discrimination in a particular restaurant affects commerce. However, the Supreme Court has upheld Congress's power to determine whether an activity affects commerce, and Congress has determined that refusals of service to African Americans burden interstate commerce. The Act only prohibits discrimination in establishments with a close tie to interstate commerce, and Congress had a rational basis for finding that racial discrimination in restaurants had a direct and adverse effect on interstate commerce.

The Supreme Court affirms the validity of the Civil Rights Act of 1964 and reverses the lower court's decision.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:A companion case to Heart of Atlanta Motel v. US....

Holding:Congress conducted prolonged hearings on the Civil Rights Act. The record...

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Katzenbach v. McClung

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