Heart of Atlanta
Motel and The Commerce Clause
How does the Commerce Clause relate
to this Event in history?
To link the Heart of Atlanta court
case to the commerce clause we need to look at what was going on in the US with
Civil Rights. President Kennedy was just getting things going when he was
assassinated. The Article below will give you a good idea of the circumstances
leading up to this important event.
Why is it significant?
The Civil Rights Act of
1964 was a revolutionary piece of legislation in the United States that
effectively outlawed egregious forms of discrimination against African
Americans and women, including all forms of segregation. The Civil Rights Act
of 1964 terminated unequal application in regards to voter registration
requirements and all forms of racial segregation in schools, in the workplace
and by facilities that offered services to the general public. When the Civil
Rights Act of 1964 was initially enacted, the powers given to enforce the act
were relatively weak; however, the authoritative abilities were later
supplemented during the years following the passing of the Civil Rights Act of
1964.
Congress asserted its
ability to enforce the Civil Rights Act of 1964 to legislate the stipulations
of the legislation through different parts of the United States Constitution. Primarily the ability to regulate interstate commerce
under Article One, the duty to guarantee all citizens equal
protection laws under the Fourteenth Amendment and the duty to protect voting
rights for all citizens under the Fifth Amendment.
Origins of the
Civil Rights Act of 1964:
President John F.
Kennedy instituted the Civil Rights Act of 1964 during his civil rights speech
of June 11, 1963, where he asked for legislation, which would give all
Americans the right to be served in public facilities.
Major Features of the
Civil Rights Act of 1964:
Title I of the Civil
Rights Act of 1964: This provision of the Civil Rights Act of 1964 barred
unequal application of voter registration requirements. Although this provision
required that all voting rules and procedures be uniform regardless of race, it
did not eliminate literacy tests, which was the predominant method used to
exclude African American voters.
Title II of the Civil
Rights Act of 1964: This particular
provision of the Civil Rights Act of 1964 prohibited discrimination in motels,
hotels, theaters, restaurants and all other public accommodations, which were
engaged in interstate commerce.
Title III of the Civil
Rights Act of 1964: Outlawed state and
municipal governments from barring access to public facilities based off an
individual’s religion, gender, race, or ethnicity.
Title IV of the Civil
Rights Act of 1964: Provision that
discouraged the desegregation of public schools and enabled the United States
Attorney General to initiate suits to enforce said act.
Title VI of the Civil
Rights Act of 1964: Prevented
discrimination by government agencies who received federal funds. If an agency
violates this particular provision of the Civil Rights Act of 1964 will lose
its federal funding.
Title VII of the Civil
Rights Act of 1964: This fundamental
provision of the Civil Rights Act of 1964 prohibited discrimination by
employers on the basis of color, race, sex, national origin, or religion.
What is the Civil Rights
Act of 1964?
The Civil Rights Act of
1964 ended racial segregation and outlawed most forms of discrimination in the
workplace, schools, public facilities and separate requirements based on
racialized distinctions, such as discriminatory voter registration
requirements. The Civil Rights Act
also clarified some of the rights of women.
Where does the authority
lie in the federal enforcement of the Civil Rights Act of 1964?
The federal government derives the power to enforce the
provisions of the Civil Rights Act through:
- Article One, Section 8 - The interstate commerce
clause as means of enforcing laws and regulations between two states.
- Fourteenth Amendment -
federal duty to guarantee all citizens equal protection under the law.
- Fifteenth Amendment -
federal duty to protect voting rights.
What are the provisions
of the Civil Rights Act of 1964?
The provisions of the
Civil Rights Act include:
- Public accommodations
may not discriminate against or segregate individuals based on race, ethnicity
of gender.
Public accommodations
being any establishments that lease, rent or sell goods and provide services.
Additionally if the establishment is public gathering place, educational
institution, park or lodging enterprises.
- School systems may no
longer segregate students, Could face federal lawsuit for non-compliance.
- A ban on racial
discrimination in employment.
- Protections for
minority voters.
These provisions are
applied in the following order in the text of the Civil Rights Act:
Title I - Rules and procedures regarding voting must be
uniform for all races.
This did not
explicitly ban forms of traditional voter suppression, such as literacy tests.
Title II - Public accommodations such as lodging,
restaurants and theaters may not discriminate on the basis of race, color,
religion or national origin.
Title III - Explicitly prohibits state and local
governments from discrimination based on race, religion color or national
origin in public facilities.
Title IV - Provides for the federal enforcement of
desegregating public schools.
Title V - Empowers the Civil Rights Commission to
further investigate and act on allegations of discrimination.
Title VI - Prohibits discrimination by federal agencies
when providing services or administration. Violating agencies can lose funding
and face judicial review.
Title VII - Bans discrimination by employers on the basis
of race, religion, color, sex or national origin. It also added for protections
for individuals associated with other races, such as an interracial marriage.
Protection did not
apply to Communist organizations or persons with Communist affiliations. Allows for limited
discrimination on the part of the employer if they can conclusively prove that
the employees’ gender would impair him or her from conducting the job properly.
Title VIII - Created a record of voter registration and
date for use by the Commission on Civil Rights.
Title IX - Moved civil rights trials with all white
juries or segregationist judges to federal courts for a fair trial.
Title X - Establish Community Relations Services to
investigate discrimination in community disputes.
Title XI - Established harsher penalties for violating
the Civil Rights Act.
How does this affect us today?
Federal vs. States
The federal government,
by nature of its role as the regulator of relations and commerce between states
enforces anti-discrimination law on business establishments.
Anti-discrimination precedent usually originates in federal courts overturning
state decisions and laws. Immediately after the establishment of the Civil
Rights Act of 1964, there arose several state challenges to the law, especially
desegregation, which sometime meant the use of federal troops to enforce
federal court decisions.
What is the legacy of
the Civil Rights Act?
Today, the US Equal
Employment Opportunity Commission investigates complaints of discrimination and
violations of the rights of employees. This has gradually expanded to the
rights of immigrants and guest workers as they face the newest wave of
discrimination in the workplace. The US government recognizes potential forms
of discrimination to include intimidation, threats of deportment, withholding
of wages and violations of Acts that proceeded after the Civil Rights Act that
guaranteed pregnancy leave, fair wages and protection for individuals with
disabilities.
Important Events and
Cases (1964)
Heart
of Atlanta Motel Inc. v. United States
As mentioned in the
previous blog and the next example of a similar court case using the commerce
clause marks a significant change in the direction would go.
Katzenbach v. McClung
This case also applied
to interstate commerce as much of the food purchased at McClung’s restaurant
crossed state lines, due to the nearby highway. The Supreme Court upheld the
right to the federal government to desegregate restaurants under the Civil
Rights Act of 1964.
Ollie’s Barbecue in
Birmingham, Alabama restaurant would only serve white people in the
restaurant and takeout to black people. Even though it may have only had a
small interstate commerce footprint, the Civil right Act of 1964 still applied
through the commerce clause.
