What was the significance of Heart of Atlanta Motel v. US?

Answer 1

Heart of Atlanta Motel v. United States, 379 US 241 (1964) challenged the constitutionality of Title II of the Civil Rights Act of 1964, as well as the authority of Congress to enact sweeping civil rights legislation and enforce it against private businesses. Title II declared discrimination in public accommodations (hotels, motels, restaurants, etc.) illegal.

The Civil Rights Act of 1964 was the first attempt to address a wide range of discriminatory practices since the US Supreme Court declared the Reconstruction-era Civil Rights Act of 1875 unconstitutional.

The earlier Act was based on the Fourteenth Amendment, Sections 1 and 5, which read:

"Section 1: All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

"Section 5: The Congress shall have power to enforce, by appropriate legislation, the provisions of this article."

In the Civil Rights Cases, 109 US 3 (1883), a consolidation of five similar cases, the Supreme Court held that Congress lacked the authority under the Fourteenth Amendment to enforce civil rights legislation against business and individuals, that the Amendment applied to the government, only. This provided legal authority allowing businesses to exclude (primarily) African-American individuals from access to public facilities and other businesses.

The decision in Civil Rights Cases appeared to strip the Legislative branch of a means of addressing inequalities.

In 1964, Congress tried a different tactic, writing anti-discrimination legislation that applied to non-government entities by invoking its powers under the Interstate Commerce Clause. The Civil Rights Act of 1964 faced immediate challenges on the grounds that Congress was overstepping its authority under Article I, and was also violating business owners' Fifth and (in the case of the Heart of Atlanta Motel) Thirteenth Amendment protections.

The Warren Court supported Congress' novel approach, ruling the law was a legitimate use of the Clause and permitted the federal government to exercise its constitutional "national police powers" to redress moral wrongs. Without such affirmation, there would have been no way to prohibit most instances of discrimination.

The decision in Heart of Atlanta reaffirmed the power of the Interstate Commerce Clause, and set a precedent for future legislation that established more powerful civil rights protections.

For more information, see Related Questions, below.