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In the midst of Civil Rights Era, Katzenbach v. McClung demonstrated the Court's commitment to equal opportunity under Constitutional interpretation. On the same day in 1964 when the Civil Rights Act was passed, Ollie McClung argued in front of the court that the Commerce Clause of the 14th Amendment did not apply to private businesses like his restaurant. He argued that his private business was sound in not seating customers of color. The court heard the case and in a unanimous decision concluded that the Commerce Clause required only a "rational basis" to be applied. In doing so, the Court ended up concluding that it can act in public interests with a rational basis standard to enforce the intent of the Constitution:
.... But where we find that the legislators, in light of the facts and testimony before them, have a rational basis for finding a chosen regulatory scheme necessary to the protection of commerce, our investigation is at an end.
The Court's decision stated that the refusal of service to African- Americans impacted "the interstate flow of food and upon the movement on products generally." The decision also confirmed the Warren Court as one of the most activist courts in the history of the Judicial Branch as it sought to make itself a vibrant participation in the discussion of Civil Rights and social equality.
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