, Title VII of the Civil Rights Act of 1964 protects employees against discrimination due to their sexual orientation or gender identity. The Supreme Court ruled under Bostock but the ruling covered all three cases. Power of Congress to enforce civil rights Civil Rights Cases, Neither the Thirteenth nor the Fourteenth Amendment empower Congress to safeguard blacks against the actions of private individuals. Heart of Atlanta Motel, Inc. v. United States, The Civil Rights Act of 1964 applies to places of public accommodation patronized by interstate travelers by reason of the Commerce Clause. Katzenbach v. McClung, The power of Congress to regulate interstate commerce extends to a restaurant that is not patronized by interstate travelers but which serves food that has moved in interstate commerce. This ruling makes the Civil Rights Act of 1964 apply to virtually all businesses. South Carolina v. Katzenbach, The Voting Rights Act of 1965 is a valid exercise of Congress's power under Section 2 of the Fifteenth Amendment. Katzenbach v. Morgan, Congress may enact laws stemming from Section 5 of the Fourteenth Amendment that increase the rights of citizens beyond what the judiciary has recognized. Jones v. Alfred H. Mayer Co., Section 1982, part of the Civil Rights Act of 1866, is constitutional under the Thirteenth Amendment and prohibits all racial discrimination in the sale or rental of property. City of Boerne v. Flores, Section 5 of the Fourteenth Amendment does not permit Congress to substantially increase the scope of the rights determined by the judiciary. Congress may only enact remedial or preventative measures that are consistent with the Fourteenth Amendment interpretations of the Supreme Court. Shelby County v. Holder, Section 4(b) of the Voting Rights Act of 1965, which contains the coverage formula that determines which state and local jurisdictions are subjected to federal preclearance from the Department of Justice before implementing any changes to their voting laws or practices based on their histories of racial discrimination in voting, is unconstitutional because it no longer reflects current societal conditions. Immunity from civil rights violations Monroe v. Pape, While municipalities can not be liable under the Civil Rights Act of 1871, individuals acting “under color of law” can be sued for damages for denying the constitutional rights of individuals. (overruled in Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978) (in part)) Pierson v. Ray, Police officers are