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. The bill’s origin emulated the Civil Rights Act of 1875; however, Kennedy’s agenda included provisions to ban all forms of discrimination in public areas while enabling the United States Attorney General to join in lawsuits against all state governments that operated or encouraged the formation of segregated schools.

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.