Consumer Non-Discrimination Act Case Study

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A florist challenges the constitutionality of the Customer Non-Discrimination Act (the CNDA) on the grounds that it exceeds Congress’s right to regulate interstate commerce and that it violates his First Amendment rights. For this case, the Court is only determining the Commerce Clause challenge. The legal question the Court must address is whether Congress has the authority, under the Commerce Clause, to enact the CNDA, which amends the Civil Rights Act of 1964 to prohibit discrimination on the basis of sex, gender identity, and sexual orientation, and additionally, expands the categories of public accommodations. To answer this question, yes, Congress does have the power to enact this legislation under the Commerce Clause for the following …show more content…

v. Lopez, Congress has the power to regulate interstate commerce under three categories: channels of commerce, instrumentalities of commerce, and activities that have an effect on interstate commerce (local or not). Of the added categories of public accommodations that are subjected to federal regulation under the CNDA, all of which could fall within the categories and not contradict with previous precedents. After U.S. v. Lopez, two major cases struck down acts that did not fall within the three categories, and thus exceeded Congress’s commerce power. In U.S v. Morrison (in addition to Lopez), the challenged statute attempted to regulate criminal activity due to its connectivity to commerce (for Morrison, it was violence against women and for Lopez, it was handguns in school zones). None of the additions to public accommodations added by the CNDA resemble criminal statutes, and all of which are related to places, goods and services, or transportation. All of these subjects fall into the categories from the Lopez precedent. Additionally, the case NFIB v. Sebelius, was struck down because Congress was attempting to regulate inactivity, as opposed to activity. This is not the case with the CNDA. No one is forced to enter the market, and thus this falls within Congress’s power to regulate. One might argue that the activities included in the CNDA are purely local, and thus have little effect on interstate commerce. However, this point has …show more content…

U.S. supported the passing of Title II of the Civil Rights Act of 1964. Under this precedent, Congress can regulate local activities that engage in discrimination because these practices have disruptive effects on interstate commerce. Under this precedent, Congress has not exceeded the power given to them under the Commerce Clause. One could argue the difference between Heart of Atlanta Motel and this case is that the motel advertised nationally and along interstate highways, while some of the activities mentioned in CNDA do not. However, this does not matter. It is rare to find a business or service that does not engage in interstate commerce in some way or another. Additionally, Heart of Atlanta Motel supports the notion that discrimination can harm interstate travel, and thus commerce. In this case, the couple who was denied service was from Massachusetts, traveling to Texas. This is similar to the ruling form Heart of Atlanta Motel because the court opinion stated that the Model's discriminatory practices would discourage African Americans from traveling to the state. Discriminatory practices, under the guise of First Amendment rights, could discourage certain people from traveling or engaging in commerce in general, which could have a negative impact on interstate commerce. For these reasons Congress has the power to regulate this commerce under the

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