What was the Heart of Atlanta Motel v. US case about?

Answer 1

Heart of Atlanta Motel v. United States, 379 US 241 (1964)

Answer

Heart of Atlanta was one of several challenges against the recently enacted Civil Rights Act of 1964, that sought to end racial discrimination in public accommodations, among other things. This case dealt exclusively with Title II, that regulated under the Article I Interstate Commerce Clause, hotels, motels, restaurants, service stations, and other businesses that were, or could potentially be, involved in interstate commerce.

Moreton Rolleston, an attorney and owner of The Heart of Atlanta Motel, petitioned the Court for an injunction against enforcing the Civil Rights Act under the claim that the act was unconstitutional, so that he could continue his policy of racial discrimination (primarily) against African-Americans.


Explanation

Attorney Moreton Rolleston, owner of The Heart of Atlanta Motel in Atlanta, Georgia, petitioned the US Supreme Court challenging the constitutionality of Title II of the Civil Rights Act of 1964. Rolleston only had standing to address Title II §§ 201 (a), (b)(1) and (c)(1) of the Act (because it directly involved his business operations), which read:

§ 201 (a)

"All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation, as defined in this section, without discrimination or segregation on the ground of race, color, religion, or national origin."

§ 201 (b)(1)

"any inn, hotel, motel, or other establishment which provides lodging to transient guests, other than an establishment located within a building which contains not more than five rooms for rent or hire and which is actually occupied by the proprietor of such establishment as his residence;"

§ 201 (c)(1)

(c) The operations of an establishment affect commerce within the meaning of this title if

(1) it is one of the establishments described in paragraph (1) of subsection (b);

The purpose of the Act, among other things, was to prohibit racial discrimination in places of public accommodation, including the petitioner's motel, which had a policy of refusing service to African-Americans.

According to Rolleston, Congress had exceeded its authority under the Article I Interstate Commerce Clause; had violated his protection under the Fifth Amendment Takings and Due Process Clauses; and had placed him in involuntary servitude, as prohibited by the Thirteenth Amendment.

Rolleston sought declatory relief (a judgment affirming specified legal rights under a contract or statute) and an injunction against enforcement of the Civil Rights Act of 1964. The United States counter-claimed for enforcement of the Act.

A three-judge panel of the District Court for the Northern District of Georgia sustained the validity of the Civil Rights Act of 1964, and issued a permanent injuntion against The Heart of Atlanta Motel, restraining them from continuing violation of the civil rights legislation. The case was sent to the US Supreme Court on expedited appeal (bypassing the usual intermediate step of being heard by the US Court of Appeals for the Eleventh Circuit). Justice Hugo Black, who had authority to oversee emergency motions for the Eleventh Circuit, sustained (ordered it to remain in effect) the District Court's injunction while the Supreme Court considered the case.


Supreme Court Decision

In the majority opinion, authored by Justice Tom C. Clark, the Court noted that The Heart of Atlanta Motel was located near the junction of two busy interstate highways, and actively solicited out-of-state business. The Court held that making rooms unavailable to African-Americans impeded the flow of interstate commerce, and was well within Congress' right to regulate.

Further, the Fifth Amendment does not prevent Congress from exercising the reasonable regulation of business.

Citing the landmark case Gibbons v. Ogden, 22 US 1 (1824), Justice Clark quoted sections of Chief Justice Marshall's opinion regarding the power of the Interstate Commerce Clause:

"It is the power to regulate; that is, to prescribe the rule by which commerce is to be governed. This power, like all others vested in Congress, is complete in itself, may be exercised to its utmost extent, and acknowledges no limitations other than are prescribed in the constitution. . . . If, as has always been understood, the sovereignty of Congress . . . is plenary as to those objects [specified in the Constitution], the power over commerce . . . is vested in Congress as absolutely as it would be in a single government, having in its constitution the same restrictions on the exercise of the power as are found in the constitution of the United States. The wisdom and the discretion of Congress, their identity with the people, and the influence which their constituents possess at elections are, in this, as in many other instances, as that, for example, of declaring war, the sole restraints on which they have relied, to secure them from its abuse. They are the restraints on which the people must often rely solely, in all representative governments."

Justice Clark concluded: "In short, the determinative test of the exercise of power by the Congress under the Commerce Clause is simply whether the activity sought to be regulated is "commerce which concerns more States than one" and has a real and substantial relation to the national interest. Let us now turn to this facet of the problem."

In framing Title II of the Civil Rights Act of 1964, Congress was legislating against what it considered a moral problem using means provided by the Constitution. The ultimate goal of the Act is not constrained by the legal process used to achieve it, as long as that process is valid, which the Court believed it was (is).

Finally, Justice Clark addressed the basis of Rolleston's other constitutional claims, stating the legislation was unlikely to cause a loss of business or income, but even if it impinged on an individual business, that is no barrier to anti-discrimination legislation. The Court found no merit in Rolleston's claims of "involuntary servitude" under the Thirteenth Amendment.

The finding of the District Court was affirmed.


For more information, see Related Questions and Related Links, below.

Answer 2

In opinion of the Court for Heart of Atlanta Motel v. United States, 379 US 241 (1964), authored by Justice Tom C. Clark, the Court held that Congress had the constitutional authority to exercise their power under the Article I Interstate Commerce Clause and apply Title II of the Civil Rights Act of 1964 to private industry.

With regard to the specific case, Clark noted The Heart of Atlanta Motel was located near the junction of two busy interstate highways, and actively solicited out-of-state business. The Court held that making rooms unavailable to African-Americans impeded the flow of interstate commerce, and was a violation of the newly enacted (and constitutional) federal law.

Finally, Justice Clark addressed the basis of Rolleston's other constitutional claims, stating the legislation was unlikely to cause a loss of business or income, but even if it impinged on an individual business, that is no barrier to anti-discrimination legislation. The Court found no merit in Rolleston's claims of "involuntary servitude" under the Thirteenth Amendment.

The finding of the District Court was affirmed.

For more information, see Related Questions and Related Links, below.

Answer 3

Heart of Atlanta Motel v. United States, 379 US 241 (1964)

A panel of three judges in the US District Court for the Northern District of Georgia upheld the Civil Rights Act of 1964, declaring Congress was within its authority to create the legislation under the Interstate Commerce Clause. The Court issued a permanent injunction against Moreton Rolleston, owner, and The Heart of Atlanta Motel as an entity, prohibiting them from discriminating against people (primarily African-Americans).

Justice Hugo Black, who had authority over the Eleventh Circuit, order the injunction remain in effect while the case was under appeal.

Heart of Atlanta was sent directly to the US Supreme Court under expedited appeal, bypassing the US Court of Appeals for the Eleventh Circuit, which would ordinarily be the first appellate step after a decision made in a US District Court within its jurisdiction (including the Northern District of Georgia).


For more information, see Related Questions and Related Links, below.