In Welsh v. Boy Scouts of America, the Seventh Circuit interpreted Title II of the Civil Rights Act of 1964. At the time of the 1964 Act, almost ninety years had passed since Congress last focused on civil rights legislation in public accommodations? While Congress clearly intended for Title II to end racial and certain other types of discrimination in public accommodations,4 congressional intent with regard to entities that do not clearly resemble any of Title II's specific examples is less clear. This Note examines the sources behind the court's decision, evaluates the court's theory of interpretation, and predicts the persuasive and precedential value of the decision for future courts' interpreting the ambiguities of Title II.

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