I. Title II of the Civil Rights Act of 1964, both in its
general plan and as applied to petitioner, is a valid
exercise of the power of Congress to regulate
interstate commerce_

A. Discrimination in places of public accom-
modation imposes burdens upon the move-
ment of interstate commerce of a kind
which Congress has power to eliminate__
Restaurants, lunch counters, etc.
Theatres and other exhibitions__
Related establishments..

B. Discrimination in hotels and motels serving
transient guests imposes burdens upon
interstate travel of a kind which Con-
gress has power to eliminate_

745-438-64——1

1. Racial discrimination in hotels and
motels, in fact, burdens inter-
state travel__.

2. Congress has power to eliminate
practices in hotels and motels
that burden interstate travel___
3. Congress may constitutionally ex-
tend its regulation of hotels and
motels to the prohibition of dis-
crimination against all guests
whether traveling in interstate or
local commerce_.

(I)

BR Zus CRh

Argument-Continued

II. Title II of the Civil Rights Act does not violate
the Fifth Amendment..

A. The prohibition of racial discrimination in
motels does not deprive appellant of
liberty or property without due process.
of law.

B. The prohibition of racial discrimination in
motels does not take appellant's prop-

erty without just compensation..

III. Title II of the Civil Rights Act does not violate the
Thirteenth Amendment..

Conclusion... ....

Appendix A____

Appendix B__ __ .

Appendix C..

Page

56

56

60

61

62

63

70

71

CITATIONS

Cases:

Ashwander v. Tennessee Valley Authority, 297 U.S.
288_.

Atlanta Biltmore Hotel Corp., 128 N.L.R.B. 364------- 51, 52
Balaban & Katz, 87 N.L.R.B. 1071

224

35

Baldwin v. Morgan, 287 F. 2d 750--

54

Bob-Lo Excursion Co. v. Michigan, 333 U.S. 28.

Brandeis & Sons, J. L. v. Labor Board, 142 F. 2d 977,

certiorari denied, 323 U.S. 751.

30

Brennan's French Restaurant, 129 N.L.R.B. 52.

Brooks v. United States, 267 U.S. 432_.

31

21

Butler v. Perry, 240 U.S. 328_

12, 61

Butts v. Merchants & Miners Transp. Co., 230 U.S.
126___

16-17

Caminetti v. United States, 242 U.S. 470---