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Heart of Atlanta Motel v. United States Case Analysis
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Heart of Atlanta Motel v. United States Case Analysis
This was an appropriate exercise ofCongressional powers under theCommerce clause because the twoprongs of the test were met.
Analysis/Application
Two part test to analyze the exercise ofpower by Congress under the CommerceClause:
1. Whether the activity sought to beregulated is commerce which concernsmore States than one.
This prong is met interstate travel, thetransportation of passengers, and themodern movement of people concerns morestates than one and is not an open question.
2. Whether there is a real and substantialrelation to the national interest.
Congress has a national interest inlegislating against the disruptive effect thatracial discrimination has on commercialintercourse (even if this is a moral question).
Rules of Law
Civil Rights Act of 1964 provisions
Section 201(a) 0f the Civil Rights Act statesthat all people are entitled to, inter alia,"accommodations of any place of publicaccommodation..." without discriminationas to color.
Section 201(b)(1) specifically defines a motelas a covered establishment, "if its operationsaffect commerce"
Section 201(c) declares that ‘any inn, hotel,motel providing lodging to transient guestsaffects commerce per se.
Section 203 prohibits withholding anyprivilege secured in Sections 201 or 202.
Commerce Clause
Commerce Clause allows Congress toregulate"commerce with foreign nations,and among the several states, and with theIndian tribes.
Current Business Practice InfluenceBy Holding of this Case
1. The way insurance plans are structured,to adhere to the ACA.
Importance for HealthcareProfessionals
This Supreme Court case stripped out someof the elements of the ACA. The Court heldthat Congress exceeded its authority underthe Commerce Clause in the "individualmandate" section of the ACA (although itwas upheld under Congressional power totax). Nat'l Fed'n of Indep. Bus. v. Sebelius,567 U.S. 519, 132 S. Ct. 2566, 183 L. Ed. 2d450 (2012)
Subsequent Impact on Caselaw
US v. Lopez Regulation of Gun Free Zones Supreme Court overturned defendant'sconviction for possessing gun in school zone, a violation of the Gun-Free School ZonesAct. The Court held that Congress exceeded its authority (and did not meet prong one ofthe test under the Heart of Atlanta Motel v. US test) because the activity to be regulateddid not arise out of and was not connected with a commercial transaction.
United States v. Lopez, 514 U.S. 549, 115 S. Ct. 1624, 131 L. Ed. 2d 626 (1995)
US v. Morrison Similar to US v. Lopez,Supreme Court struck down the civilremedy portion of the Violence AgainstWomen Act (VAWA), saying that Congressexceeded its authority and "Congresstherefore may not regulate noneconomic,violent criminal conduct based solely onthe conduct's aggregate effect oninterstate commerce."
United States v. Morrison, 529 U.S. 598,120 S. Ct. 1740, 146 L. Ed. 2d 658 (2000)
Gonzales v. Raich Congress was within itsauthority to ban marijuana (even though CApermits it) because its an economic activity,and the government has a number ofinterests in regulating the drugtrade/criminal activity.
Gonzales v. Raich, 545 U.S. 1, 125 S. Ct.2195, 162 L. Ed. 2d 1 (2005)
Conclusion/Holding
Congress appropriately passed thechallenged provisions of the Civil Rights Actunder its authority granted by theCommerce Clause of the Constitution.
Motel had to comply with Civil Rights Actand serve patrons of color
Facts
Parties
Heart of Atlanta Motel Original Plaintiff,Current Appellant
United States, Appellee
Factual Background
Heart of Atlanta ("HOA") is a motel inAtlanta that is centrally located and solicitsinterstate guests 75% of guests are fromout of state.
Prior to Civil Rights Act of 1964, HOArefused to rent to black individuals.
Procedural History
Heart of Atlanta filed suit in the USDistrict Court for the NorthernDistrict of Georgia seekingdeclaratory judgment and injunctiverelief from the publicaccommodations provisions of theCivil Rights Act. The District Courtdenied HOA's request for relief, andHOA appealed.
