Katzenbach v. McClung
Following is the case brief for Katzenbach v. McClung, 379 U.S. 294 (1964)
Case Summary of Katzenbach v. McClung:
- Ollie’s Barbecue in Alabama refused to serve African-Americans in the dining area, and only allowed African-Americans to get food through take-out service.
- The owner of Ollie’s sued to prevent enforcement of the Civil Rights Act of 1964 on his restaurant, claiming that his one restaurant did not impact interstate commerce.
- The district court agreed with Ollie’s Barbecue.
- The U.S. Supreme Court, however, reversed the district court.
- It held that Ollie’s discriminatory conduct was subject to Congress’ commerce power, and thereby subject to the Civil Rights Act. The Court reasoned that if all restaurants discriminated in the way that Ollie’s did, then such conduct would have a substantial impact on interstate commerce.
Katzenbach v. McClung Case Brief
Statement of the Facts:
Ollie McClung had a restaurant, Ollie’s Barbecue, in Alabama. He allowed white people to dine in, but African-Americans were only permitted to get food by take out. Ironically, over two-thirds of his employees were African-American. The restaurant was located on a major road in Birmingham. Half of the restaurant’s food came from outside Alabama, and it served many customers from outside the state.
McClung sued in federal court to enjoin the federal government from enforcing the Civil Rights Act of 1964 on his restaurant. He argued that his restaurant had no impact on interstate commerce, and that he did provide a means to serve African-Americans – through take out service.
Procedural History:
- The federal district court agreed with McClung, and barred enforcement of the Civil Rights Act against the restaurant.
- The U.S. Supreme Court agreed to hear the appeal from the district court, along with a companion case Heart of Atlanta Motel v. United States, which dealt with racial discrimination at hotels and motels.
Issue and Holding:
Does the Civil Rights Act of 1964 prohibit racial discrimination by a restaurant? Yes.
Judgment:
The decision of the United States District Court for the Northern District of Alabama is reversed.
Rule of Law or Legal Principle Applied:
The Civil Rights Act of 1964 does apply to a single restaurant because if all restaurants behaved the way the discriminating restaurant did, then there would be a substantial impact on interstate commerce. Thus, the federal government has the authority to regulate the discriminatory acts of a restaurant.
Reasoning:
The Civil Rights Act applies to places of public accommodation, including restaurants. Further, using the rationale of Wickard v. Filburn, even though Ollie’s single restaurant may not have an impact on interstate commerce by itself, if all restaurants discriminated against African-Americans the way that Ollie’s does, then such discrimination would have a massive impact on interstate commerce. Congressional evidence shows that discriminating against African-Americans does depress interstate commerce.
Congress’ commerce power is broad, and the Civil Rights Act can be enforced under its authority. Indeed, the Civil Rights Act is appropriate to resolving a national commercial problem – racial discrimination – of the first magnitude.
Significance:
Katzenbach v. McClung is a significant desegregation case. Allowing a broad reading of the Commerce Clause, the Court was instrumental in tearing down the discrimination in many establishments, and in preserving the progress achieved by civil rights activists in the 1960s.
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