Heart of Atlanta Motel v. United States

379 U.S. 241 (1964), argued 5 Oct. 1964, decided 14 Dec. 1964 by vote of 9 to 0; Clark for the Court, black, Douglas, and Goldberg concurring. Heart of Atlanta Motel was the major constitutional test of the public accommodations provisions (Title II) of the Civil Rights Act of 1964 as well as an important reaffirmation of Congress's broad powers under the Commerce Clause. A motel owner in Atlanta, whose motel served mostly transient interstate travelers, refused to serve blacks as required by the act. He claimed that Congress had exceeded its Commerce Clause authority to regulate private businesses and also that the act was invalid under the Fifth Amendment's Due Process Clause and the Thirteenth Amendment.

A three‐judge U.S. district court upheld Title II and permanently enjoined the motel from discriminating on account of race. The Supreme Court unanimously affirmed. Justice Tom Clark, citing Gibbons v. Ogden (1824) and a long line of cases upholding Congress's plenary power to regulate under the Commerce Clause, held that Congress could regulate both interstate commerce and intrastate activities that affected commerce as part of its “national police power” to legislate against moral wrongs.

Congress employed the Commerce Clause as primary authority for the act because the Civil Rights Cases (1883), as then interpreted, prohibited it from enforcing the Fourteenth Amendment against privately owned restaurants and hotels. Justices William O. Douglas and Arthur Goldberg, however, claimed that the statute could have been upheld under section 5 of the Fourteenth Amendment as well.

In Katzenbach v. McClung (1964), a companion case that tested the act's applicability to a small, essentially intrastate restaurant (“Ollie's Barbecue”), the Court found that even though the restaurant's customers were local, it purchased much of its food and supplies through interstate commerce and thus was also covered. Taken together the two cases provided a major impetus to congressional efforts to legislate on behalf of civil rights.

See also Commerce Power; Race and Racism.

— Steven Puro

• 379 U.S. 241 (1964)
• Vote: 9–0
• For the Court: Clark
• Concurring: Black, Douglas, Goldberg

The Civil Rights Act of 1964 was the most comprehensive civil rights legislation passed by Congress since 1875. Title II of this law prohibited discrimination on the grounds of race, color, religion, or national origin in public accommodations involved in any way in interstate commerce. Its goal was to end discrimination in facilities such as hotels, motels, restaurants, concert halls, theaters, and sports arenas.

Congress based its power to regulate such businesses on the commerce clause in Article 1, Section 8, of the Constitution, which gives Congress the power to regulate commerce among the states. A case challenging the use of the commerce power by Congress to prevent racial discrimination reached the Supreme Court only a few months after the passage of the 1964 Civil Rights Act.

The Heart of Atlanta Motel in downtown Atlanta, Georgia, defied the new law by refusing to rent rooms to blacks. The motel owner claimed that Congress had exceeded its authority under the commerce clause by enacting Title II to regulate local businesses, such as hotels, that were open to the public.

The owner also argued that Title II violated his 5th Amendment rights. The 5th Amendment says that no person shall be “deprived of life, liberty, or property, without due process of law.” The motel owner claimed the new Civil Rights Act regulated his private property “without due process of law.”

The Issue

The case represented a major test of a key part of the new Civil Rights Act. The Constitution gave Congress the clear right to regulate interstate commerce. But did this commerce power permit Congress to prohibit discrimination in privately owned accommodations open to the public within a single state?

Opinion of the Court

The Supreme Court unanimously upheld Title II of the Civil Rights Act as a legitimate exercise of the commerce power. Justice Tom Clark, a former district attorney from Texas, wrote that the motel did engage in interstate commerce because it sought out-of-state customers by advertising in national publications and 75 percent of its guests were interstate travelers. Citing testimony from the congressional hearing on the act, Justice Clark pointed out that the difficulty blacks encountered in obtaining accommodations frequently discouraged them from traveling. The model's discrimination therefore obstructed interstate commerce.

Next, Clark defined the meaning of the commerce power of Congress. He declared that Congress's power to regulate interstate commerce also gave it the authority to regulate local business that “might have a substantial and harmful effect” on interstate commerce.

Clark added that the fact that Congress had used its powers under the commerce clause to achieve a moral goal—stopping discrimination—had no bearing on the decision. “Congress was not restricted by the fact that the particular obstruction to interstate commerce with which it was dealing was also deemed a moral and social wrong,” he wrote.

Finally, the Court rejected the charge that Title II violated the motel owner's 5th Amendment rights to private property. “In a long line of cases this Court has rejected the claim that the prohibition of racial discrimination in public accommodations interferes with personal liberty,” declared the opinion.

Significance

The Supreme Court's decision affirmed that Congress has the constitutional power to promote equality of opportunity and to prevent discrimination. The case greatly aided the cause of the civil rights movement of the 1960s, putting a solid constitutional foundation under legislative and political efforts to promote equal rights for African Americans.

See also Civil rights; Commerce power; Equality under the Constitution

Heart of Atlanta Motel v. United States
Supreme Court of the United States
Argued October 5, 1964 Decided December 14, 1964
Full case name	Heart of Atlanta Motel, Incorporated v. United States, et al.
Citations	379 U.S. 241 (more) 85 S. Ct. 348; 13 L. Ed. 2d 258; 1964 U.S. LEXIS 2187; 1 Empl. Prac. Dec. (CCH) P9712
Prior history	Judgment for defendant, 231 F.Supp. 393 (N.D. Ga. 1964). Appeal from the United States Court of the Northern District of Georgia
Subsequent history	None
Holding
Congress did not unconstitutionally exceed its powers under the Commerce Clause by enacting Title II of the 1964 Civil Rights Act, which prohibited racial discrimination in public accommodations. Northern District of Georgia affirmed.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan, Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Clark, joined by Warren, Douglas, Harlan, Brennan, Stewart, White, Goldberg
Concurrence	Black
Concurrence	Douglas
Concurrence	Goldberg
Laws applied
U.S. Const. art. I; Title II of the Civil Rights Act of 1964

Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241 (1964) ^[1], was a landmark United States Supreme Court case holding that the U.S. Congress could use its Commerce Clause power to fight discrimination.

Contents 1 Background 2 The case 3 Decision 4 See also 5 References

Background

This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for "separate but equal" treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans. During the mid-twentieth century, partly as a result of cases such as Powell v. Alabama, 287 U.S. 45 (1932); Smith v. Allwright, 321 U.S. 649 (1944); Shelley v. Kraemer, 334 U.S. 1 (1948); Sweatt v. Painter, 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents, 339 U.S. 637 (1950); NAACP v. Alabama, 357 U.S. 449 (1958); Boynton v. Virginia, 364 U.S. 454 (1960) and probably the most famous, Brown v. Board of Education of Topeka, 347 U.S. 483 (1954), the tide against segregation began to turn. However, segregation remained in full effect in parts of the southern United States, where the Heart of Atlanta Motel was located, despite these decisions into the 1960s.

The case

Passed on July 2, 1964, the Civil Rights Act of 1964 banned racial discrimination in public places, particularly in public accommodations, largely based on Congress' control of interstate commerce.

The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act violated his Fifth Amendment rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process of law and just compensation. Finally, the owner argued that Congress had placed him in a position of involuntary rent available rooms to blacks, thereby violating his Thirteenth Amendment rights.

In response, the United States countered that the restrictions in adequate accommodation for black Americans severely interfered with interstate travel, and that Congress, under the United States Constitution's Commerce clause, was certainly within its power to address such matters. Moreover, they argued, the Fifth Amendment does not forbid reasonable regulation of interstate commerce and such incidental damage did not constitute the "taking" of property without just compensation or due process of law. Third, they argued that the Thirteenth Amendment applied primarily to slavery and the removal of widespread disabilities associated with it; in such kind, the Amendment certainly would not place issues of racial discrimination in public accommodations beyond the reach of Federal and state law.

The District court ruled in favor of the United States and issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination in terms of the goods or services that it offered to guests or the general public upon its premises. The owner of the motel was Attorney Moreton Rolleston. This case was combined with the case of the future Governor of Georgia Lester Maddox concerning his Pickrick restaurant and his case to refuse to serve blacks.

Decision

Announced on December 14, 1964, the opinion of the court was delivered by Justice Tom C. Clark, with concurring opinions by Justice Arthur Goldberg, Justice Hugo Black, and Justice William O. Douglas.

The Court held that Congress acted well within its jurisdiction of the Interstate Commerce clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it hard to conceive that such an Amendment might possibly be applicable in restraining civil rights legislation. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75 and 85 as well as two major U.S. Highways, the Court found that the business clearly affected interstate commerce. As such, it therefore upheld the permanent injunction issued by the District Court, and required the Heart of Atlanta Motel to receive business from clientele of all races.

See also

• List of United States Supreme Court cases, volume 379
• Katzenbach v. McClung

References

1. ^ Text of Heart of Atlanta Motel v. United States, 379 U.S. 241 (1964) is available from:  · Enfacto · Findlaw

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