Table of Contents
Supreme Courts serve to evaluate the constitutionality of lower level criminal courts and other law enforcement agencies. Supreme Court case summaries provide a framework for careful analysis and interpretation of court cases (Ducat, 2008). The underlying argument is that having an understanding of the court decisions is one of the preliminary requirements for having an understanding of the constitutional principles towards the solution of particular court cases. In most cases, Supreme Court interpretations usually have an effect on the effect on the constitutional principles applied during the quest for solving a case between two parties. This paper aims at providing an in-depth understanding of the Supreme Court interpretations through outlining the Supreme Court case summary of Heart of Atlanta Motel Versus the United States. The essay will provide an overview of the parties involved during the case, the facts of the case, the legal issues, and the court’s decision. In addition, the paper will highlight the significance of the court case.
Heart of Atlanta Motel, Inc. v. United States (December 14, 1964)
The parties involved in the case
The case was between the owner of the Heart of Atlanta Motel and the United States Congress. The case number 379 U.S 241(1964) was an opportunity that the United States congress had to use in order to alleviate discrimination based on race; in particular, the congress used the Commerce clause found in the US constitution (Miller & Vandrome, 2010). The Heart of Atlanta Motel used to offer accommodation to the public, although it did not provide accommodation to the black people. The US congress on the other hand had the authority to regulate intestate commerce, and as result prohibited racial discrimination in public places, laying a keen emphasis on places that offered accommodation to the public. In filing the case, the owner of the motel aimed at challenging the contents of the Civil Rights Act passed during 1964, in regard business proprietors to select their clients (Menez & Vile, 2004).
Facts of the case
The Civil Rights Act of 1964, under title II prohibited discrimination based on racial grounds on businesses that offered accommodation to the public, especially if the operations of such businesses significantly affected interstate commerce. In this respect, the Heart of Atlanta Motel did not provide accommodation to black clients, and faced charges for the violation of Title II of the Civil Rights Act (Miller & Vandrome, 2010).
Legal issues in the case
According to the Civil Rights Act, public places should not provide their services basing on racial bias. This implies that the United States Congress controlled much of interstate commerce. The Heart of Atlanta Motel violated the Civil Rights Act by refusing to provide accommodation services to black people. The motel proprietor, Attorney Moreton Rolleston argued that the act granted excess authority to the US congress in terms of controlling interstate commerce. The owner of the motel contested that the Civil Rights Act infringed his right to choose clients and operate his business the way he prefers, which is a provision under the Fifth Amendment (Ducat, 2008). According to the motel proprietor, he was deprived of his property in a process that did not put into consideration the provisions of the law.
The Motel owner also claimed that the US congress had put him in a state of involuntary servitude, compelling him to rent rooms that were available to black people (Ducat, 2008). As a result, the owner claimed that the state violated the Thirteenth Amendment rights (Miller & Vandrome, 2010). The case question was to determine whether the US congress had granted itself excessive powers in the Commerce clause during the passage of the Civil Rights Act during 1964, especially under the Title II. The owner of the motel argued that the commerce clause powers deprived motel businesses such as the Heart of Atlanta their right to customer choice (Miller & Vandrome, 2010).
In response to the claims by the Heart of Atlanta motel, the United States argued that the US congress had the powers to address issues associated with racial discrimination since restrictions in providing accommodation for black Americans significantly affected their travel between different states (Ducat, 2008). This is a provision under the Commerce clause found in the US constitution. Moreover, the US argued that the regulation of interstate commerce is provided for in the Fifth Amendment, and that such actions does not sum up to any sort of damage to warrant for compensation.
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According to the US, the whole operation followed the due process of the law (Ducat, 2008), in addition, the process did not involve taking of the owner’s property as claimed by the motel owner. In countering the claims of the motel owner, that the state violated his Thirteenth Amendment rights, the state claimed that the Thirteenth amendment was only applicable to matters that involved slavery and the alleviation of disparities related to slavery. Therefore, the Thirteenth amendment cannot position cases that involve racial discrimination in public places at the expense of the United States Federal law and the state laws (Ducat, 2008).
The Supreme Court ruling was in favor of the United States, stating that the US congress had the mandate and power to enforce prohibitions during scenarios that involves racial discrimination in places that provided public accommodation (Menez & Vile, 2004). This was a provision under the commerce clause and a section of the Civil Rights Act that dealt with public accommodation. The presiding Judge, Justice Thomas Clark, reviewed a congressional testimony that outlined how the mobility of the African Americans between the various states was being impaired due to issues such as racial discrimination. Justice Clark also noted that the course of action for the state to eliminate racial discrimination was a valid approach.
There were no merits in the claims of violation of the Thirteenth Amendment by the motel owner (Miller & Vandrome, 2010). Therefore, the claims of the motel owner were invalid in this context. The judge also noted that most of the customers who visited the Heart of Atlanta motel were from outside the state and that its strategic location played a significant role in affecting interstate commerce, basing on this, the presiding judge only saw it appropriate if the motel provided accommodation to all races so as to promote interstate commerce.
Summary of majority of the opinions
The legal provision for the case based on the Civil Rights Act of1964. The court’s decision based on the voting of nine judges, which resulted to all of them voting for the United States. Most of the judges wrote a statement of concurrence with the final decision of the jury, arguing that racial discrimination in places that provided public accommodation was not justified. In addition, racial discrimination in the Motel affected interstate trade in a great capacity (Menez & Vile, 2004).
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Significance of the case
The case challenged the validity of the Civil Rights Act passed during 1964, which was a milestone in the quest to eliminate discrimination based on racial grounds. Prior to 1964, segregation was evident in the American society that significantly made the lives of Black Americans difficult through inferior accommodation services and bad treatment. The case significantly changed the perceptions towards the Black Americans and played an important role in eliminating racism in the US (Miller & Vandrome, 2010). The court’s decision was justified because the state has the power to regulate interstate commerce and eliminate racial discrimination, as under the provisions of the law. In this context, all the claims by the motel owner have no base in the provisions of the US constitution; they are therefore invalid in this case.
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