Wednesday, November 6, 2013

Katzenbach v. McClung, Sr. & McClung, Jr. case brief

Katzenbach v. McClung, Sr. & McClung, Jr. case brief summary
379 U.S. 294 (1964)

CASE SYNOPSIS
Appellant acting attorney general sought review from a judgment of the United States District Court for the Northern District of Alabama, which issued an injunction restraining appellant from enforcing the Civil Rights Act of 1964 against appellee restaurant.

CASE FACTS
An injunction restraining appellant from enforcing Title II of the Civil Rights Act of 1964 against appellee came before the court on direct appeal. The court stated that it was important that a decision on the constitutionality of the Act be announced quickly because interference with governmental action had occurred. Appellee served food procured via interstate commerce and served interstate travellers, but refused to serve Negroes.


DISCUSSION

  • The district court held that the Commerce Clause did not apply because there was no demonstrable connection between food purchased in interstate commerce and the conclusion of Congress that discrimination in the restaurant would affect commerce. 
  • The court stated that the enforcement of Title II had already been found to be a valid exercise of the power to regulate commerce by requiring hotels to serve transients without regard to their race or color and held it was equally valid in the case of restaurants. 
  • By refusing to serve Negroes, the restaurant spent less money, restricted the ability of Negroes to travel interstate, and obstructed interstate commerce. 
  • The court therefore held the regulatory scheme of Title II was valid.

CONCLUSION
The court reversed the judgment.

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