Katzenbach v. McClung

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Katzenbach v. McClung
Seal of the United States Supreme Court.svg
Argued October 5, 1964
Decided December 14, 1964
Full case nameNicholas Katzenbach, Acting Attorney General, et al. v. Ollie McClung, et al.
Citations379 U.S. 294 (more)
85 S. Ct. 377; 13 L. Ed. 2d 290; 1964 U.S. LEXIS 2188; 1 Empl. Prac. Dec. (CCH) P9713
Prior history233 F. Supp. 815 (N.D. Ala. 1964)
Holding
Section 201(a), (b), and (c) of the Civil Rights Act of 1964[1] which forbids discrimination by restaurants offering to serve interstate travelers or serving food that has moved in interstate commerce is a constitutional exercise of the commerce power of Congress.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · William O. Douglas
Tom C. Clark · John M. Harlan II
William J. Brennan, Jr. · Potter Stewart
Byron White · Arthur Goldberg
Case opinions
MajorityClark, joined by Warren, Harlan, Brennan, Stewart, White
ConcurrenceDouglas
ConcurrenceGoldberg
ConcurrenceBlack
Laws applied
Title II of the Civil Rights Act of 1964[1]

Katzenbach v. McClung, 379 U.S. 294 (1964), is a landmark decision by the United States Supreme Court. The Court held that Congress acted within its power under the Commerce Clause of the United States Constitution in forbidding racial discrimination in restaurants as this was a burden to interstate commerce. The ruling was a 9–0 decision in favor of the plaintiff—the United States government. It was also a test case of the Civil Rights Act of 1964.[2] In particular,

Background[change | change source]

Ollie's Barbecue was a family-owned restaurant that operated in Birmingham, Alabama, that seated 220 customers. It was located on a state highway and was 11 city blocks from an interstate highway. In a typical year, approximately half of the food it purchased from a local supplier came from out-of-state. It catered to local families and white-collar workers. However, they refused to serve African American customers in the restaurant.[a][4] About 24 of the 36 employees of the restaurant were black.[5]

Congress passed the Civil Rights Act of 1964[1] outlawing segregation in American schools and public places. One section of the act, Title II, was specifically intended to grant African-Americans full access to public facilities such as hotels, restaurants, and public recreation areas. On the same day, the Supreme Court heard challenges to Title II from a motel owner[b] and from Ollie McClung. Both claimed that the federal government had no right to impose any regulations on small, private businesses. Both ultimately lost. Ollie McClung had won in the United States District Court for the Northern District of Alabama when he received an injunction preventing the Government from enforcing Title II against his restaurant. But then U.S. Attorney General Nicholas Katzenbach, appealed this decision to the U.S. Supreme Court.[5]

Opinion of the Court[change | change source]

McClung argued that the Civil Rights Act was unconstitutional, at least as applied to a small, private business such as his. McClung further argued that the amount of food purchased by Ollie's that actually crossed state lines (about half of the food at Ollie's) was so small that Ollie's effectively had no effect on interstate commerce (although McClung admitted that a significant amount of Ollie's business was to interstate travelers). Because of this, McClung argued that Congress had no power to regulate Ollie's Barbecue under the Commerce Clause.

The court ruled unanimously that the Civil Rights Act is constitutional and that it was properly applied against Ollie's Barbecue.[6]

Justice Clark wrote the majority opinion, with concurrences by Justices Black, Douglas, and Goldberg.[7] In section 2 of the opinion, the Court agreed with McClung that Ollie's itself had virtually no effect on interstate commerce. In section 4 of the opinion, the Court held that racial discrimination in restaurants had a significant impact on interstate commerce, and therefore Congress has the power to regulate this conduct under the Commerce Clause.[8] The Court's conclusion was based on extensive Congressional hearings on the issue.

Later developments[change | change source]

After decades in operation, Ollie's Barbecue moved to the suburb of Pelham in 1999 and closed in 2001.[9]

Notes[change | change source]

  1. "Title II of the Civil Rights Act of 1964 prohibits discrimination because of race, color, religion, or national origin in certain places of public accommodation, such as hotels, restaurants, and places of entertainment. The Department of Justice can bring a lawsuit under Title II when there is reason to believe that a person has engaged in a pattern or practice of discrimination in violation of Title II. The Department can obtain injunctive, but not monetary, relief in such cases. Individuals can also file suit to enforce their rights under Title II and other federal and state laws may also provide remedies for discrimination in places of public accommodation."[3]
  2. The case was Heart of Atlanta Motel, Inc. v. United States.

References[change | change source]

  1. 1.0 1.1 1.2 Civil Rights Act of 1964
  2. "Desegregation - Katzenbach v. McClung, 1964". Tarlton Law Library. Archived from the original on 10 September 2015. Retrieved 26 March 2016.
  3. "Title II of the Civil Rights Act (Public Accommodations)". U.S. Department of Justice. Retrieved 26 March 2016.
  4. "Katzenbach v. McClung". CaseBriefs. Retrieved 26 March 2016.
  5. 5.0 5.1 "Katzenbach v. McClung". Berkman Center for Internet & Society/ Harvard Law School Library. Retrieved 26 March 2016.
  6. "Katzenbach v. McClung". IIT Chicago-Kent College of Law. Retrieved 26 March 2016.
  7. "Katzenbach v. McClung". The Heritage Foundation. Retrieved 26 March 2016.
  8. "Katzenbach v. McClung – Case Brief Summary". Lawnix. Archived from the original on 25 March 2016. Retrieved 26 March 2016.
  9. Ollie's BBQ closes, but the sauce will live on, Birmingham Business Journal, Friday, September 21, 2001.