Katzenbach v. McClung

Background

A family-owned restaurant in Birmingham, Alabama, refused to serve Black customers in its dining room since it opened in 1927. The restaurant seats 220, employs 36 people (about two-thirds Black), and bought roughly $150,000 in food locally, about $69,683 of which had moved in interstate commerce. A federal district court had enjoined enforcement of the Civil Rights Act against the restaurant, and the Government appealed.

Reasoning

The central question was whether Congress lawfully could apply the Civil Rights Act to restaurants that serve a substantial portion of food brought in from other States. The Court reviewed Congress’s lengthy hearings showing that racial refusal reduced spending by Black customers, discouraged interstate travel, and harmed local business, and it explained that such local actions, taken together, can substantially affect interstate commerce. Relying on past Commerce Clause decisions, the Court held that Congress had a rational basis to reach restaurants that either serve interstate travelers or serve food a substantial portion of which has moved in interstate commerce. The Court therefore reversed the lower court and found the Act valid as applied to the restaurant.

Real world impact

Because the ruling enforces Title II against restaurants meeting those criteria, such restaurants cannot legally refuse service based on race when they sell substantial interstate-sourced food or serve interstate travelers. The decision affirms Congress’s power to regulate local businesses that have a clear connection to interstate commerce and resolves the case by reversing the injunction against enforcement.