Cengage Advantage Books: Business Law Today, The Essentials 10th Edition by Roger LeRoy Miller

تمرين 13

Heart of Atlanta Motel v. United States
HISTORICAL AND SOCIAL SETTING In the first half of the twentieth century, state governments sanctioned segregation on the basis of race. In 1954, the United States Supreme Court held that racially segregated school systems violated the Constitution. In the following decade, the Court ordered an end to racial segregation imposed by the states in other public facilities, such as beaches, golf courses, buses, parks, auditoriums, and courtroom seating. Privately owned facilities that excluded or segregated African Americans and others on the basis of race were not subject to the same constitutional restrictions, however. Congress passed the Civil Rights Act of 1964 to prohibit racial discrimination in "establishments affecting interstate commerce." These facilities included "places of public accommodation."
FACTS The owner of the Heart of Atlanta Motel, in violation of the Civil Rights Act of 1964, refused to rent rooms to African Americans. The motel owner brought an action in a federal district court to have the Civil Rights Act declared unconstitutional on the ground that Congress had exceeded its constitutional authority to regulate commerce by enacting the statute. The owner argued that his motel was not engaged in interstate commerce but was "of a purely local character." The motel, however, was accessible to state and interstate highways. The owner advertised nationally, maintained billboards throughout the state, and accepted convention trade from outside the state (75 percent of the guests were residents of other states). The district court ruled that the act did not violate the Constitution and enjoined (prohibited) the owner from discriminating on the basis of race. The owner appealed. The case ultimately went to the United States Supreme Court.
ISSUE Did Congress exceed its constitutional power to regulate interstate commerce by enacting the Civil Rights Act of 1964?
DECISION No. The United States Supreme Court upheld the constitutionality of the act.
REASON The Court noted that the act was passed to correct "the deprivation of personal dignity" accompanying the denial of equal access to "public establishments." Testimony before Congress leading to the passage of the act indicated that African Americans in particular experienced substantial discrimination in attempting to secure lodging while traveling. This discrimination impeded interstate travel and thus impeded interstate commerce.
As for the owner's argument that his motel was "of a purely local character," the Court said that even if this was true, the motel affected interstate commerce. According to the Court, "if it is interstate commerce that feels the pinch, it does not matter how local the operation that applies the squeeze." Therefore, under the commerce clause, "the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities."