Katzenbach v. McClung facts for kids
Quick facts for kids Katzenbach v. McClung |
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Argued October 5, 1964 Decided December 14, 1964 |
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Full case name | Nicholas Katzenbach, Acting Attorney General, et al. v. Ollie McClung, et al. |
Citations | 379 U.S. 294 (more)
85 S. Ct. 377; 13 L. Ed. 2d 290; 1964 U.S. LEXIS 2188; 1 Empl. Prac. Dec. (CCH) P9713
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Prior history | 233 F. Supp. 815 (N.D. Ala. 1964) |
Holding | |
Section 201(a), (b), and (c) of the Civil Rights Act of 1964 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 | |
Case opinions | |
Majority | Clark, joined by Warren, Harlan, Brennan, Stewart, White |
Concurrence | Douglas |
Concurrence | Goldberg |
Concurrence | Black |
Laws applied | |
Title II of the Civil Rights Act of 1964 |
Katzenbach v. McClung was an important case decided by the U.S. Supreme Court in 1964. This case was about whether the U.S. government could stop racial discrimination in restaurants. The Court decided that the U.S. Congress had the power to do this.
They said that refusing to serve people because of their race affected interstate commerce. This means it affected business and trade between different states. The ruling was a unanimous 9-0 decision. It was also a key test for the new Civil Rights Act of 1964.
Contents
What Happened in the Case?
Ollie's Barbecue: A Local Restaurant
Ollie's Barbecue was a restaurant in Birmingham, Alabama. It was owned by a family and could seat 220 customers. The restaurant was located near a state highway. It was also close to a major interstate highway.
About half of the food Ollie's bought each year came from outside Alabama. The restaurant served local families and office workers. However, Ollie's Barbecue refused to serve Black customers inside the restaurant. About 24 of the 36 employees at Ollie's were Black.
The Civil Rights Act of 1964
In 1964, Congress passed the Civil Rights Act of 1964. This law made it illegal to separate people by race in schools and public places. One part of this law, called Title II, aimed to give Black Americans full access to public places. This included hotels, restaurants, and public recreation areas.
On the same day, the Supreme Court heard challenges to Title II. One challenge came from a motel owner. The other came from Ollie McClung, the owner of Ollie's Barbecue. Both argued that the federal government could not tell small, private businesses what to do.
The Legal Challenge
Ollie McClung had first won his case in a lower court. That court stopped the government from making his restaurant follow Title II. But then, U.S. Attorney General Nicholas Katzenbach appealed this decision. He took the case to the U.S. Supreme Court.
The Supreme Court's Decision
McClung's Argument
McClung argued that the Civil Rights Act was against the Constitution. He said it should not apply to a small, private business like his. McClung also argued that the small amount of food Ollie's bought from other states did not affect interstate commerce much.
Because of this, McClung believed Congress did not have the power to regulate his restaurant. This power comes from the Commerce Clause of the Constitution.
The Court's Unanimous Ruling
The Supreme Court ruled that the Civil Rights Act was constitutional. They also said it was correctly applied to Ollie's Barbecue. The decision was unanimous, meaning all nine justices agreed.
Justice Clark wrote the main opinion for the Court. Justices Black, Douglas, and Goldberg also wrote separate opinions agreeing with the decision.
The Court agreed with McClung that Ollie's Barbecue alone had little effect on interstate commerce. However, the Court looked at the bigger picture. They said that racial discrimination in many restaurants had a big effect on interstate commerce. This meant Congress did have the power to stop this behavior under the Commerce Clause. The Court based its decision on many hearings Congress had held about this issue.
What Happened Next?
Ollie's Barbecue operated for many more years. In 1999, it moved to a different town called Pelham, Alabama. The restaurant finally closed its doors in 2001.