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Heart of Atlanta Motel v US1964

Heart of Atlanta Motel v US 1964
Facts
Parties
Heart of Atlanta Motel
United State of America
What Happened
Heart of Atlanta Motel is a 216 room motel
located at the intersection of two
interstates in Atlanta, Georgia
Heart of Atlanta Motel hosts mostly out of
state guests
Heart of Atlanta Motel would like to
continue to exclude black Americans from
staying there
Heart of Atlanta has a no black
Americans policy and would like
to continue this policy
Heart of Atlanta Motel sued the United
State of America to find the Civil Rights
Act of 1964 unconstitutional as
exceeding the Commerce Clause
Procedural History
The case was initially tried in the Northern
District Court of Georgia in 1964 the Court
ruled against Heart of Atlanta Motel
The lower court held Title II of the Civil
Rights Act of 1964 as constitutional
The lower court issued a permanent
injunction requiring the Heart of
Atlanta Motel to refrain from racial
discrimination
Heart of Atlanta Motel appealed, and
the Supreme Court of the United States
decided to hear the case without it
proceeding through the 11th Circuit.
Impact
US v Alfonso LOPEZ,Jr (1995)
Alfonso Lopez brought a gun to school
and was convicted of violating the Gun
Free School Zones Act of 1990
The trial court found the defendant
guilty. He appealed and the court of
appeals had to decide whether congress
exceeded its Commerce Cause power by
extending it to activities that don't have
an apparent connection to interstate
commerce
The Supreme Court held the court of
appeals decisions that the possession of a
hangun near school is not an activity that
has a substantial effect on interstate
commerce.
This case is important because it limited
The Congress's power to use the
Commerce Clause to regulate issues.
US v Jean MARTIGNON (2004)
Jean Martignon operated Midnight
Records and was indicted by a federal
grand jury for selling unauthorized
recordings of live performances
Jean Martignon moved to dismiss the
Indictment on the basis that the
antibootlegging statute is unconstitutional
because it was to broad and did not limit
the statutes reach.
The government cited many past cases
including Heart of Atlanta Motel, Inc. v
United States and Congress's ability to
enact legislation under its Commerce
Clause but the court agreed it was too
broad.
This case uses similar reasoning
to the Heart of Atlanta case,
however it helps illustrate that
congress's power under the
Commerce Clause are not
unlimited.
Issue Before the Court
Whether congress exceeded its Commerce
Clause power by depriving motel the right
to choose its customers
Influence
Sexual Orientation Discrimination
"Deprivation of personal dignity that surely
accompanies denials of equal access to
public establishments,” Heart of Atlanta
Motel, Inc. v. United States, means that an
antidiscrimination law fulfills its purpose
when it reaches all, not simply most, public
accommodations
Telescope Media Group v. Lindsey (2017)
ADA Compliance
The Supreme Court upheld the
constitutionality of the public
accommodations provisions of the Civil
Rights Act of 1964 in Heart of Atlanta
Motel, Inc. v. United States. The Supreme
Court agreed that Congress possessed the
authority to outlaw discrimination in public
accommodations on the basis of race. Heart
of Atlanta Motel, Inc., Congress acted again
to outlaw discrimination in public
accommodation.
Civil Rights Education and Enforcement
Center v Hospitality Properties Trust
(2017)
Rule of Law
Congress can regulate local activities that
substantially affect interstate commerce
Means of regulation are okay as long as
the end is constitutional
Plaintiff must show that the requirements
of Civil Rights Act of 1964 exceeded the
authority granted to congress over
interstate commerce
5th Amendment
Plaintiff must show that the Civil Rights Act
of 1964 violated its 5th amendment and
resulted in unjust deprivation of its property
Application
The US argues that congress did not
unconstitutionally exceed its powers under
the Commerce Clause by enacting Title II
of the 1964 Civil Rights Act, which
prohibited racial discrimination in public
accommodations.
The court observed that 75% of the Heart
of Atlanta Motel's clientele came from
outofstate, and that it was strategically
located near Interstates 75 and 85 as well
as two major Georgia highways, the Court
found that the business clearly affected
interstate commerce.
The U.S. Supreme Court held that
Congress acted well within its authority
under the Commerce Clause in passing the
Civil Rights Act of 1964, thereby upholding
the act's Title II in question.
Congress was within its authority because
Courts gave broad deference to congress
on commerce clause issues that involved
free movement of people
The plaintiff has the burden of proving...
The court was not within its authority
under the Commerce Clause to pass
the Civil Rights Act of 1964
In fact, the court exceeded its authority in
passing this law
Its 5th amendment rights were violated
and this impacted the use of property and
compensation
Conclusion
The US Supreme Court upheld the
permanent injunction issued by
the district court
This prevented Heart of Atlanta from
discriminating against patrons based on
race
163
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