Summary
Katzenbach v. McClung, 379 U.S. 294 (1964), was a U.S. Supreme Court case which confirmed that Congress did indeed act within the powers of the Commerce Clause, giving to them under Article I, Section 8, Clause 3 of the Constitution of the United States, when they prohibited discrimination in public settings, such as motels and restaurants, due to its negative effects on interstate commerce. As restaurants like the white owned Ollie’s Barbecue, in Birmingham Alabama would soon realize.
Similarly to the case of Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241 (1964) before it, Katzenbach was another case closely tied to the Civil Rights Act of 1964, an act which had sought out to not only prohibited segregation of colored people in public places, but also banned discrimination based on race, religion, color and sex.
With yet another unanimous decision of 9-0, the Supreme Court held that racial discrimination in restaurants would play a significant impact on interstate commerce, due to African Americans spending little to no time in areas that still had segregated public establishments. In essence, the discouragement of African American spending due to areas of segregation would imposed a sort of artificial restriction to the flow of merchandise.
Katzenbach v. McClung 379 U.S. 294 (1964). (n.d.). Retrieved April 28, 2016, from https://supreme.justia.com/cases/federal/us/379/294/case.html
Background
no
Issues
Are the powers given to Congress under the Commerce Clause enough to allow them to force private businesses to abide by Title II of the Civil Rights Act?
Does a restaurant’s refusal to serve blacks burden interstate commerce to an extent that Congress can legitimately prohibit such discrimination?
Decision
Justice Warren – No
Justice Black – No (Concurrence)
Justice Douglas – No (Concurrence)
Justice Clark – No (Majority Opinion)
Justice Harlan – No
Justice Brennan – No
Justice Stewart – No
Justice White – No
Justice Goldberg – No (Concurrence)
The Court unanimously ruled that the Civil Rights Act was in fact constitutional and was being appropriately applied to against Ollie’s barbecue. Holding that racial discrimination in restaurants had a significant impact on interstate commerce because African Americans spent significantly less time in areas that had racially segregated restaurants. This segregation imposed an artificial restriction on the flow of merchandise because many African Americans were discouraged from making purchases in segregated establishments.
Katzenbach v. McClung 379 U.S. 294 (1964). (n.d.). Retrieved April 28, 2016, from https://supreme.justia.com/cases/federal/us/379/294/case.html
Majority Opinion (author)
no
Concurring Opinion (author)
no
Dissenting Opinion (author)
no
Full Text of Opinions
Concurring Opinion (Black)
Concurring Opinion (Douglas)
Concurring Opinion (Goldberg)
Significance / Impact
no
Constitutional Provisions
The constitutional provisions discussed in Katzenbach V. MCclung (1964) is whether Title II of the Civil Rights Act of 1964, which prohibits the neglection of goods or services to the public due to race, color, religion, or national origin. Defining under Section 201(b) establishments as places of public accommodation if their operations affect commerce or segregation. Focusing that an establishment can be qualified as affecting commerce when it serves interstate travelers food and services. It questions the power to exercise interstate commerce under Title II of the Act, and if it gives Congress the power to intervene with restaurants that receive a yearly income of $70,000. Finally, if in fact this restaurant can be considered to be a commerce burden under Title II.
“Katzenbach v. McClung 379 U.S. 294 (1964).” Justia Law. Accessed May 01, 2016. https://supreme.justia.com/cases/federal/us/379/294/case.html.
Major Statute(s) Under Review
The Civil Rights Act of 1964
Important Precedents
no
Important Subsequent Cases
no
Web Resources
no
Academic Books, Articles and Law Reviews
no
Contributors
Spring 2016: Gabriela Batista-Vargas, Sana Cheema, Vaughn Fray, Zenobia Haynes, & Francisca Stevens