Heart of Atlanta Motel, Inc. v. United States

1、FACTS

This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875.

For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for “separate but equal” treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans. This case hinged on whether the federal government has the power to make private discrimination a crime.

2、ISSUE

Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers?

3、HOLDING/REASONING

The Supreme Court ruled that Congress had the power under the Commerce Clause to enact the prohibitions on discrimination contained in the public accommodations section of the Civil Rights Act of 1964. Justice Thomas Clark wrote the opinion for a unanimous Court. He reviewed testimony presented at congressional hearings showing that Americans had become increasingly mobile, but that African Americans were discriminated against by hotels and motels, and often had to travel longer distances to get lodging or had to call on friends to put them up overnight.

Justice Clark noted that under the Interstate Commerce Act, “the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the States of origin and destination, which might have a substantial and harmful effect upon that commerce. One need only examine the evidence which we have discussed above to see that Congress may-as it has-prohibit racial discrimination by motels serving travelers, however 'local' their operations may appear.”

Justice Clark also found that the Act did not deprive the motel owner of liberty or property under the Fifth Amendment. Because Congress has the right to prohibit discrimination in accommodations under the Interstate Commerce Act, the motel “has no 'right' to select its guests as it sees fit, free from governmental regulation.”

4、CASE COMMENTARY

During this era of Commerce Clause jurisprudence, actions by the federal government under this power were upheld if they regulated an activity that affected more than one state and had a substantial overall effect on national commerce. Although this case was important and influential, coming early in the Civil War era, the arguments that Rolleston advanced were so dubious at face value that the outcome was never seriously in doubt.

二、Shelley v. Kraemer

1、FACTS

The Petitioners had purchased a home burdened by restrictive covenants that excluded non-whites from purchasing real property in the neighborhood. The Respondents, Kraemer and others (Respondents), had brought an action in state court seeking to enforce the covenant provisions. The state court upheld the provisions and ruled the Respondents were entitled to an injunction prohibiting the Petitioners from occupying the property. The Supreme Court of the United States (Supreme Court), in analyzing the case, stated that the Equal Protection Clause of the Fourteenth Amendment of the Constitution, applied only to state action and not to the conduct of private individuals. Next, the Supreme Court stated that the restrictive covenants prohibiting non-whites from purchasing property in the neighborhood was a private action and thus did not violate the Fourteenth Amendment of the Constitution. The Supreme Court then reasoned that the enforcement of the restrictive covenants by a state court triggered state action, thus, permitting the Petitioners to argue their Fourteenth Amendment rights were violated.

2、ISSUE

Whether the Equal Protection Clause of the Fourteenth Amendment of the constitution inhibits judicial enforcement by state courts of restrictive covenants based on race or color?

3、HOLDING/REASONING

Held. Yes. Judgment of the lower state courts reversed. Among the civil rights intended to be protected from discriminatory state action by the Fourteenth Amendment of the Constitution are the rights to acquire, enjoy, own and dispose of property. However, the patterns of discrimination are by terms of agreements among private individuals. The action inhibited in the first section of the Fourteenth Amendment of the Constitution is only the state’s action. Therefore, the restrictive covenants standing alone cannot be regarded as violative of any rights guaranteed by the Fourteenth Amendment of the Constitution. However, since the purposes of the agreements and the restrictive terms of the agreements were secured only by judicial enforcement by state courts, such state action results in a violation of equal protection. Thus, the Equal Protection Clause of the Fourteenth Amendment of the Constitution inhibits judicial enforcement by state courts of restrictive covenants based on race or color.

4、CASE COMMENTARY

This was a groundbreaking case at the time because it expanded the scope of what conduct can be considered state action under the Fourteenth Amendment. Since then, many laws at federal, state, and local levels have unambiguously banned discrimination in private residential housing.

三、Marbury v. Madison

1、FACTS

In the final days of John Adams’presidency he appointed a multitude of justices of the peace under the “Organic Act” deliberately because the oncoming President Thomas Jefferson would not.  The commissions were signed and sealed but were not delivered.  President Jefferson later refused to honor the commissions because they had gone undelivered until Jefferson had held office and therefore felt they were invalid. Marbury, one of the appointees, later applied to the supreme court for a writ of mamandus, claiming that the Supreme Court could issue such writ “… to any courts appointed, or persons holding office, under the authority of the United States.”

2、ISSUE

（1）Is Marbury’s appointment valid?

（2）Whether the Supreme Court can award the writ of mandamus.

（3）Whether the Supreme Court has judicial review power.

（4）Is offering the writ of mandamus the appropriate remedy for the court?

3、HOLDING/REASONING

（1）Yes. It is valid because the appointment was done in full while Adams was still President.  He completed the entire task of the appointment process and did all he could do in such completion.  The appointment is valid when the President undertakes his final act required for the appointment, not upon delivery of the appointment which is beyond the President’s control.  Marbury is entitled to appointment as a remedy because it was a right given to him by President Adams. In this sense, Marbury was given “a specific right.”  The very essence of government is to provide remedies to rights that are abridged.

（2）Yes, the appointment was a legal right offered to Marbury; and for every legal right violated, the law must afford a remedy.  As such, his remedy is the rightful entitlement to the appointment.  The delivery of the appointment was simply “ministerial” and therefore was owed to him.  The appointment had already occurred prior to the necessity of delivery; and once the appointment was granted, Marbury had a vested legal right.

（3）Yes, but not in the instant case. The Judiciary Act of 1789 clearly gives the Supreme Court judicial review over writs of mandamus.  However, Article III of the Constitution does not give the Supreme Court authority to review the writs.  Therefore, the two laws are in conflict.  As such, the Supreme Court – being charged with upholding the Constitution – must adopt Article III’s application.  Justice Marshall argued that there would be no point for the Supreme Court to exist were it not to uphold the Constitution and strike down laws adopted by Congress that necessarily conflict with the Constitution itself.  In so doing, Marshall established the principle of judicial review.

（4）Yes, but in the instant case the Constitution conflict with the Judiciary Act of 1789 and therefore the remedy cannot be proffered.  In this case, a writ of mandamus is appropriate because it is an order for a public official to carry out his duty.  But for the reasons explained in (3), the order cannot be carried out.

4、CASE COMMENTARY

The Supreme Court uses its own understanding of the Constitution in reviewing the legitimacy of acts by other branches of the government, even though this power is not apparent from the plain text of the document. This case established the legitimacy of judicial review as well as the primacy of the Constitution over any other source of law. Many legal scholars of both Marshall's period and the contemporary era found the opinion's logic strained, basing a sweeping conclusion on relatively little textual support. Still, the concept of judicial review has long been accepted without challenge.

Unfortunately for Marbury, he never received his appointment as a justice of the peace in the District of Columbia, merely because the commission was not delivered before Adams left office.