Katzenbach v. McClung
Katzenbach v. McClung was a significant Supreme Court case in 1964 that addressed the intersection of civil rights and interstate commerce. The case involved Ollie's Barbecue, a local restaurant in Alabama that refused to serve African American customers, citing its operations as purely local and therefore beyond federal jurisdiction. However, the Supreme Court ruled that the restaurant’s practices fell under the Commerce Clause, as even a small amount of its food could be traced back to interstate commerce. This landmark decision reinforced the federal government's authority to combat racial discrimination in public accommodations, particularly through the lens of the 1964 Civil Rights Act. The ruling marked a pivotal shift in constitutional interpretation, as it effectively diminished the distinction between interstate and intrastate commerce, allowing for broader congressional power to address civil rights issues. The case stands as a crucial moment in the ongoing struggle for racial equality in the United States, highlighting the legal steps taken to dismantle segregationist practices in everyday life.
Katzenbach v. McClung
Date: December 14, 1964
Citation: 379 U.S. 294
Issues: Racial discrimination; commerce clause
Significance: This decision represents the broadest interpretation of the commerce clause ever issued by the Supreme Court.
Early in U.S. history, the Supreme Court made a distinction between interstate commerce, which was regulated by the federal government, and intrastate commerce, which was the province of the states. Starting with National Labor Relations Board v. Jones and Laughlin Steel Corp. (1937), the Court began abandoning the distinction, and, by the time of Katzenbach, it was virtually gone. In Katzenbach, Ollie’s Barbecue, a family-owned restaurant that bought its food locally and served people from the area, refused to seat African Americans. The Court ruled that the commerce clause applied, giving Congress power to regulate discrimination, because even a small portion of the food served may have moved in interstate commerce. The Court also found that the restaurant’s discriminatory practices violated the public accommodations provision of the 1964 Civil Rights Acts. This decision considerably broadened the powers of Congress to regulate commerce.
