Daniel v. Paul
23 L. Ed. 2d 318, 395 U.S. 298, 1969 U.S. LEXIS 1438 (1969)
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Rule of Law:
A recreational facility is a 'place of public accommodation' under Title II of the Civil Rights Act of 1964 if it either contains a covered establishment, such as a snack bar serving food that has moved in interstate commerce, or qualifies as a 'place of entertainment' using sources of entertainment that have moved in interstate commerce.
Facts:
- Euell Paul and his wife owned and operated the Lake Nixon Club, a 232-acre recreational facility near Little Rock, Arkansas, which included amenities for swimming, boating, miniature golf, and a snack bar.
- The Pauls operated the club in a racially segregated manner, consistently denying admission to Black patrons.
- Following the enactment of the Civil Rights Act of 1964, the Pauls began referring to the facility as a 'private club' and charged a 25-cent 'membership' fee, though white individuals were routinely admitted.
- Rosalind Daniel and other Black residents of Little Rock were refused admission to the Lake Nixon Club solely because of their race.
- The club's snack bar served hot dogs, hamburgers, soft drinks, and milk; ingredients for the bread and soft drinks originated from outside Arkansas.
- The club leased 15 paddle boats on a royalty basis from an Oklahoma company and used a jukebox and records that were manufactured out-of-state.
- The Pauls advertised the club in media intended to reach tourists and interstate travelers, including a magazine distributed at hotels, on radio stations, and in a newspaper for a local Air Force Base.
Procedural Posture:
- Rosalind Daniel and other Black petitioners filed a class action lawsuit against Euell Paul, the owner of Lake Nixon Club, in the U.S. District Court for the Eastern District of Arkansas.
- The District Court found that petitioners were denied entry due to their race but dismissed the complaint, holding that Lake Nixon was not a 'public accommodation' under the Civil Rights Act of 1964.
- The petitioners appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals affirmed the trial court's decision, with one judge dissenting.
- The petitioners then successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a privately-owned recreational facility that denies admission based on race qualify as a 'place of public accommodation' subject to Title II of the Civil Rights Act of 1964 if it operates a snack bar serving food with out-of-state ingredients and utilizes recreational equipment that has moved in interstate commerce?
Opinions:
Majority - Justice Brennan
Yes, a privately-owned recreational facility like the Lake Nixon Club qualifies as a 'place of public accommodation' under Title II of the Civil Rights Act of 1964. The Court provided two independent reasons for this conclusion. First, the snack bar is a covered establishment under § 201(b)(2) because a 'substantial portion' of the food it serves (ingredients for bread and soft drinks) has moved in interstate commerce, and it offers to serve interstate travelers through its advertising. Because the snack bar is covered, the entire facility falls within the Act's ambit under § 201(b)(4). Second, the club itself is a 'place of entertainment' under § 201(b)(3). Rejecting a narrow interpretation limited to spectator entertainment, the court held the term includes participatory recreational areas. The club's operations 'affect commerce' because its 'sources of entertainment'—such as paddle boats leased from Oklahoma and an out-of-state jukebox—moved in interstate commerce.
Dissenting - Justice Black
No, the Lake Nixon Club does not qualify as a 'place of public accommodation' because its operations do not 'affect commerce' as required by the Civil Rights Act of 1964. The majority's holding stretches the Commerce Clause beyond its intended limits. There is no concrete evidence that any interstate traveler ever patronized the facility; the Court's conclusion is based on speculation and 'iffy' conjectures. Furthermore, the record is devoid of evidence that a 'substantial portion' of the food served had moved in interstate commerce, and relying on judicial notice for bread ingredients is improper. This ruling gives the federal government control over every remote, local place of recreation, which goes too far and erodes the distinction between local and national matters.
Concurring - Justice Douglas
Yes, the facility is covered, and while I join the majority's opinion, I also rest my conclusion on the Fourteenth Amendment. The segregation of Black people in public facilities is a 'badge of second-class citizenship' and a relic of slavery. Such discrimination constitutes a denial of the privileges and immunities of national citizenship and the equal protection of the laws guaranteed by the Fourteenth Amendment, providing an alternative constitutional basis for the Act's application.
Analysis:
This decision significantly broadened the scope of the Civil Rights Act of 1964 by expansively interpreting both what constitutes a 'place of entertainment' and what 'affects commerce.' By including participatory recreational facilities and setting a very low threshold for interstate commerce connections (e.g., food ingredients or leased equipment), the Court made it difficult for local businesses to evade Title II's anti-discrimination mandate. The ruling armed civil rights plaintiffs with powerful arguments to bring seemingly local establishments under federal jurisdiction. It solidified the principle that if any part of an establishment is covered by the Act, the entire establishment is subject to its provisions.
