There have been numerous cases challenging the power of the Congress in regulating local business under the Commerce Clause. Some of them stated that the latter had exceeded its powers by interfering with small local entities, which did not have a large impact on interstate commerce. This research elucidates the extent of congressional power under the Commerce Clause by discussing theUnited States v. Bates,Wickard v. Filburn, United States v. Darby Lumber Corporation,andHeart of Atlanta Motel v. the United Statescases as well as the Equal Access Act.

Wickard v. Filburn Case

Filburn took the case before the Supreme Court in a move to bid the court in order to declare the Federal Crop Insurance Program unconstitutional. According to this case, the production quotas as provisioned by the Agricultural Adjustment Act (1938) were to apply to agricultural production under the Constitution. The reason behind the provision was that the agricultural products would be consumed purely interstate. The ruling argued that the case effect upon interstate commerce was placed within the power of Congress to control it.

Relationship to the United States v. Bates Case

The Congress control of commerce in theUnited States v. Batescase was developed on constitutional grounds. In 1942, the US Supreme Court increased the power of Congress to control commence in a large way. InWickard v. Filburncase, this section is referenced by code 317 U.S. 111 (1942). Thus, the Supreme Court found that Congress should only exercise those powers quoted in the Constitution. The Equal Access Act was already a law since Congress had passed it, and it was signed by the president.

Congress had the right to exercise the control of the Commerce Act in Bates’ case due to the law of equal access to all the facilities offered by Bates in his establishment. According to the Act, all persons irrespective of the sexual orientation are entitled to equal access to hotels, restaurants, motels, barber shops, gasoline stations, and all entertainment establishments. Bates’ establishment provided a service covered under the Equal Access Act. Bates’ move to stop Congress in allowing same-sex couples to access equal facilities did not have a solid ground.

The reason is that Bates operated the Eros Lodge and the Eros Bar and Grill which are classified as entertainment entities under the Equal Access Act. Similar toWickard v. Filburn, Congress exercised its power within the parameters stipulated in the national Constitution. The Act is anonymous and created for the general welfare of all citizens protected by the Constitution. Bates worries about allowing same-sex couples in his establishment could have been seen as an act of discrimination based on sexual orientation. If he would have denied same-sex couple access to his facilities, it could have legally sued him for discrimination.

United States v. Darby Lumber Corporation Case

This case is related to the hypothetical case in question regarding theUnited States v. Bates. According to the Fair Labor Standards Act established in 1938, Congress sought to regulate the minimum wage and maximum working hours for staffs in manufacturing plants for interstate commerce. The FLSA provisioned that violators of the Act would be fined heavily or serve a jail term. Darby was arrested after he shipped his goods out the state. He was charged with the violation of the FLSA (1938). The court ruled that the FLSA was a constitutional exercise of the Congressional power governed by the Commerce Clause.

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Relationship to the United States v. Bates Case

In theUnited States v. Bates, Bates spends $20,000 annually on interstate goods. This is related to theUnited States v. Darbyin that Bates shipped his goods from a different state. His establishment also draws customers from the State of Disarray every year though most of his customers come from his state, the State of Grace. Although his business serves most of the local clientele, the fact that he also serves clients from the State Disarray makes his business an interstate operating entity. Consequently, Congress has every power to regulate all actions related to interstate commerce.

According to theUnited States v. Darby Lumber Corporation, the Congress had the authority to create and enforce labor standards for any form of manufacturing meant for interstate commerce (Epstein and Walker). Although the Supreme Court accepted to review in theUnited States v. Batescase, it cannot interfere with the Congress decision on interstate commerce. In reference to theUnited States v. Darby Lumber Corporationcase, the Supreme Court could not interfere with any purpose and motive the Congress might have for exercising its powers as provisioned under the Interstate Commerce Act.

InBates, the Congress only allowed same-sex couples to have access to commercial establishments in the State. Consequently, he argued that Congress did not have any grounds backed by the Constitution on any laws and standards concerning immoral conduct. It is arguable that his claims were based on the doubts related to whether there are specific rights that mandate equal treatment of same-sex couples in all public accommodation facilities under the Fourteenth Amendment.

In response to Bates’ theory, there are no specific sections in the law governing the equal treatment of same-sex couples in boarding places. However, Congress relies on the Commerce Clause to justify the law. This can be accessed in Article I, Section 8, and Clause 3. Bates offers accommodation services both locally and internationally. Therefore, this makes his entity an interstate commerce establishment, which can also be evidenced in Darby, in theUnited States v. Darby Lumber Corporationcase (Epstein and Walker). Thus, Bates has no claim to any actions that might be undertaken by Congress in its roles of regulating interstate commerce.

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Equal Access Act

It was created in the US in 1984 seeking to compel federally funded institutions to give the students irrespective of their sexual orientation equal access to extracurricular formations. In the case study ofUnited States v. Bates,Congress passed the Equal Access Act to compel all entities operating under the Commerce Clause to offer their services to individuals irrespective of their sexual orientation.The United States v. Batesis connected to the Equal Access Act in two ways, namely, Bates’ establishment lies under the listed entities in the Equal Access Act and to protect all persons from discrimination.

Bates challenged the Equal Access Act by filing a suit in the Federal District Court, on behalf of the State of Grace to create an injunction against the law being passed. He sorts to challenge the law’s constitutionality. According to this claim, it is not true that the law was beyond the Congress power on interstate commerce. Equal Access Act applies to all establishments listed in the Act’s paragraph. Such entities are inclusive of Bates’ establishment, all of which affect interstate commerce to a certain degree. The entities listed include those dealing with interstate travel, traffic, communication, and trade.

The law assumes that inns, motels, hotels, etc. operating in the modern American Economy directly or indirectly affect interstate commerce. Entities that serve food and/or beverages affect interstate commerce by the meaning of the law if they serve interstate travelers. They also affect interstate commerce if a large volume of the foods and beverages served has moved using interstate commerce. By this definition, Bates’ establishment is an interstate commerce entity serving interstate travelers and using $20,000 worth of interstate meals and beverages.

Protect Persons from Discrimination

The Equal Access Act protects all individuals from discrimination as stated in the Constitution. In the past, discrimination has been evidenced in the form of racial segregation. For instance, South Africa had the worst recorded instances of racial discrimination before the creation of the Civil Rights Act in 1964. The bad effects of discrimination can be supported by the recently publicized controversies such as the equal rights for homosexuals. There was also the economic aftermath of boycotts, for example, the boycott of Colorado after a state’s constitutional amendment was passed, allowing special protection for homosexuals.

Although Bates had concerns for his establishment if same-sex couples were allowed to have access to his establishment, the Equal Rights Act was passed for a good course. It protects the citizens and all members of the nation against discrimination due to their sexual orientation. Past surveys results in the United States have shown that same-sex couples have been deterred from traveling, patronized in restaurants, etc. because of discrimination. In respect to this, Bates’ actions to challenge the passing of the Equal Rights Act are not based on the public concern about discrimination but on personal grounds to protect his establishment.

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Heart of Atlanta Motel v. the United States Case

TheUnited States v. Batesis also related to the case ofHeart of Atlanta Motel v. the United States. In this case, the Congress outlawed discrimination of persons in entities that offered accommodation following the Civil Rights Act of 1964. The motel owner in Atlanta refused to serve African Americans due to racial discrimination. In this case, Congress had the mandate to exercise its powers in controlling discrimination in the Atlanta Motel. The motel offered accommodation to interstate travelers; thus, it is liable to answer to the regulations enacted by Congress. This is under the Commerce Clause.

Relationship to the United States v. Bates Case

In theHeart of Atlanta Motel v. the United States case, Congress has the right to restrict any form of discrimination in hotel and boarding establishments under the Commerce Clause. Such discrimination could be not only due to racial origin but also to sexual orientation. In reference to this argument, Bates’ actions against same-sex couples can be stated to instances of discrimination. Consequently, Congress has a right to outlaw his actions as well as it did in theHeart of Atlanta v. the United Statescase.

The Best Case to Decide Bates

The best case that can help in ruling thei>United States v. Batesis theUnited States v. Darby Lumber Corporationcase. The latter has a close connection to the former since Bates shipped goods to use in the establishment from a different state, the State of Disarray. This makes his entity an interstate commerce one that should be governed by the Congress under the Commerce Clause. In addition, similar to theUnited States v. Darby Lumber Corporationcase, the Supreme Court cannot interfere with the decisions made by the Congress under the Commerce Clause. This means that although the Supreme Court has takenBatesfor reviewing, it will not interfere with the Congress ruling since Bates’ entity is an interstate commerce business.


Congress has the power to control interstate business operations under the Commerce Clause. In theUnited States v. Bates, Congress had the right to allow equal access to his establishment for all persons irrespective of their sexual orientation. Bates did not have a solid ground in creating an indictment opposing the passing of the Equal Access Act. The reason is that the Act was developed to protect all individuals against any form of discrimination.

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