1964 Civil Rights Act: Heart of Atlanta Motel v. US - A Legal Challenge - Research Paper

Introduction

Following the enactment of the Anti-Discrimination bill that became Title II of the 1964 Civil Right Act, a legal challenge was filed against the US administration in the federal court. The objective of the suit involved challenging Title II of the 1964 Civil Act. The case included Heart of Atlanta Motel, Inc. v. United States in which the primary arguments for both the defendant as well as the plaintiff are outlined below, along with the reasons the inspired the federal court to make its ruling.

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Firstly, the Atlanta Motel's challenged Title II by contending that by enacting the Act, Congress surpassed its Commerce Clause influence to regulate interstate commerce. Secondly, the owners contended that the Act dishonored their rights of the Fifth Amendment by taking away their right to operate their business organization and select their clients based on their desires (Heart of Atlanta Motel, Inc. v. United States 379 U.S. 242). Finally, the Motel owners contended that the law violated their rights of the Thirteenth Amendment by positioning them in a situation of involuntary servitude through compelling them to rent vacant rooms to the African Americans (Atlanta Motel, v. U.S. 379 U.S. 261).

The US government's attorneys responded to the allegations of the Atlanta Motel's owners by contending that public accommodation restrictions for the black Americans in public shelters significantly affected state to state travel, and it was the Congress' obligation to solve such issues. Additionally, they contended that the 5th amendment allows the regulation of state to state commerce. Lastly, the government argued that even though 13th amendment primarily pertained to slavery as well as the removal of slavery associated disabilities was not applicable in the ongoing case (Atlanta Motel v. U.S. 379 U.S. 244).

According to the ruling made by JC (Justice Clark), it was determined that Congress performed appropriately within its power of the Interstate Commerce Clause in issuing the 1964 Civil Rights Law. The law court observed that Title II's application was restricted to businesses having a substantial and undeviating relation with the state to state flow of people and commodities. The court discovered that the Motel's business influenced interstate commerce as it had a strategic location neighboring interstate 85 and 75 and two major highways as well as 75 % of its customers were from outside the state (Atlanta Motel v. U.S. 379 U. S. 274).

The court came into a conclusion that public places of accommodation were not allowed to discriminate guests. Consequently, the holding was not applicable to Title II as it was partly founded on the State-to-State Commerce Clause. The court elaborated the congress' authority to manage interstate businesses such as the activities that significantly influence interstate commerce thus attaining an authentic end.

The question on the Congress' power under the State to State Commerce Clause led the court to determine whether Congress was rational to deduce that motels' racial discrimination influenced interstate commerce and if the selected means of management were appropriate. Congress had sufficient proof that racial prejudice negatively affected interstate commerce. As such the court mentioned that Congress had the capability to solve the problem.

Lobel's opening contention was on Woodland's dereliction to assert the private golf club exclusion as confirmatory defenses thus it was not raised at this point. Lobel's proposal for summary ruling involved the argument that Woodland had violated the Americans with Disability Act by depriving him full and equivalent enjoyment of the golf club due to his disability. He argued that the golf club's denial to provide him with a SoloRider to use on the club's putting greens as well as the bunkers denied him rational adjustment of the club's Woodland's golf cart principles.

Lobel contended that the club's actions indicated lack of membership regulation (Lobel v. Woodland Golf Club of Auburndale 144). The plaintiff argued that the club's decision to refuse a SoloRider on its bunkers, as well as greens was utterly mobilized by the golf club's an-authorized members such as Mucciarone and Garfinkel, the club's superintendent and general manager respectively (Lobel v. Woodland 144).

Additionally, Lobel argued that the general manager's participation in Woodland's daily management such as editing the club's website, receiving of member demands, fielding and responding to external inquiries pointed toward lack of control over club operations. Lobel further contended that the golf club uses its website and Facebook page to market and publicize itself as well as promoting its members to the people on a continuous basis (Lobel v. Woodland 144).

Lobel also argued that the club permitted the public to ask for membership information. Lobel contended that in spite of limited guest rule, the golf club allows for the access of non-members during functions, including golf tournaments and weddings (Lobel v. Woodland 145). As such, Lobel's conclusive argument was that a huge number of non-members were frequent at the club's annual events and functions as well as had the access to its facilities.

Woodland mainly contended that it was not under the scope of ADA's Title III as it was a privately owned golf club (Lobel v. Woodland 138). The court made a ruling that Woodland was excluded from the necessities of the ADA as it was a private club, and thus, the club was entitled to swift judgment (Lobel v. Woodland 147). The undoubted facts proved Woodlands to be a private club with accordance to ADA as its members controlled its operations; it exercises honest selectivity when it comes to member admission; it does not advertise its members to the public, and non-members are not accepted to utilize the club's amenities.

Contrary evidence such as the denial of a few applicants' admission or the access of some outsiders to the club's facilities was not sufficient enough to rule otherwise (Lobel v. Woodland 147). A private club is able to maintain its status even if it has associations with the rest of the world, and its tendency to host charitable functions. The public accommodations regulation pat the federal level, particularly Title II of the 1964 Civil Rights Act (CRA) is applicable to a constricted set of profitable entities where it inhibits the discernment based on gender, race national origin, or color (Epstein 1242).

However, following the revision of Statute 651.065, the new legislation highlighted that it is not unlawful, as well as not a basis for civil action for public accommodation places to provide either special offers or differential pricing packages based on sex. Concerning these two assertions, the following section of this paper will analyze the both the legality, as well as the conflict that may arise between the two laws.

This paper asserts that the Nevada's revised statute (651.065) does not conflicts with the more superior law, which is Title II of the nondiscriminatory CRA of 1964, particularly on the aspect of access and pricing. Instead, what the Nevada legislation did was to an extension for Title II of the 1964 CRA law. Even though some may argue that the issue of pricing in the context of sex, particularly when accessing the night clubs is discriminatory against gender, the revised statute clearly allows for equal access of public accommodation units, along with an exemption of differential pricing for special offers based on sex provided the intention is for promotion.

As such one may argue that both Nevada's revised statutory regulation, as well as the federal law including Title II of the 1964 Civil Rights Act forbids discrimination in nightclubs while the statute exempts promotion of the same areas. In support of this contention, Sepper, Nevada's revised statute allows the lean-to special deals based on "citizen discounts or ladies' nights" (643). In the state of Nevada, free entrance into night clubs is commonly known as lady's night, and is regarded as a form of promotional activity.

Admittedly, the regulation concerning such promotional activities may not be uniform across all states. Nonetheless, at the federal level in the USA, courts often find such practices to be issues of the state mainly due to the fact that the challenges highlighted under the Fourteenth Amendment's Equal Protection Clause lack merit due to the absence of state action as noted by Dhooge (331). In its place, successful assertions against organization conducting discriminatory promotions rely on local as well as state law. For instance, in 2008, the Equal Rights Commission of Nevada found that an LA Athletic club was unable to offer unrestricted membership to female members as a form of its marketing approach, which resulted in challenges to Las Vegas practice of permitting women free entrance by nightclubs. However, the in 2011 the legislature of Nevada responded to such claims by officially declaring the revised 651.065 statute.

Works Cited

Dhooge, Lucien J. "Public Accommodation Statutes and Sexual Orientation: Should There Be a Religious Exemption for Secular Businesses." Wm. & Mary J. Women & L. 21 (2014): 319-340.

Epstein, Richard A. "Public Accommodations under Civil Rights Act of 1964: Why Freedom of Association Counts as a Human Right." Stan. L. Rev. 66 (2014): 1241.

Sepper, Elizabeth. "The Role of Religion in State Public Accommodations Laws." . Louis ULJ 60 (2015): 631-650

Cases

Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241, 85 S. Ct. 348, 13 L. Ed. 2d 258 (1964).

Lobel v. WOODLAND GOLF CLUB OF AUBURNDALE, 260 F. Supp. 3d 127 (D. Mass. 2017).