Appellant
Heart of Atlanta Motel, Inc.
Appellee
United States
Appellant's Claim
That provisions of the Civil Rights Act of 1964, requiring hotel and motel owners to provide accommodations to African Americans, cannot be enforced against privately owned public accommodations.
Chief Lawyer for Appellant
Moreton Rolleston, Jr.
Chief Lawyer for Appellee
Archibald Cox, U.S. Solicitor General
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark (writing for theCourt), William O. Douglas, Arthur Goldberg, John Marshall Harlan II, PotterStewart, Earl Warren, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
14 December 1964
Decision
By a unanimous decision, the Supreme Court upheld the public accommodations provisions of the Civil Rights Act of 1964.
Significance
Heart of Atlanta Motel marked a turning point in Congress' efforts topromote civil rights through use of its power to regulate interstate commerce.
The Heart of Atlanta Motel was a 216-room establishment located in downtown Atlanta, Georgia, close to several interstate highways. The motel advertised in national magazines and on billboards within Georgia. Approximately 75 percent of the motel's registered guests came from out of state.
In 1964, Congress passed a civil rights act intended to eliminate racial discrimination. Some of the act's most important provisions appeared in a sectionknown as Title II, which insured full access to places of public accommodation to racial minorities. Prior to passage of the act, the Heart of Atlanta Motel had consistently refused to supply African Americans with rooms. Claimingthat it was the motel's right as a private business to continue this practice, the motel operator filed suit in the U.S. District Court for the NorthernDistrict of Georgia, seeking a judicial declaration that Title II was unconstitutional, as well as an injunction preventing the enforcement of the publicaccommodations provisions.
The federal government countersued, seeking enforcement of the act against the hotel. The government prevailed in district court, and the hotel operatorsappealed this judgment to the U.S. Supreme Court.
Supreme Court Affirms Congressional Authority to Regulate Private Businessunder the Commerce Clause
Justice Clark, writing for a unanimous Court, upheld the power of Congress under the Commerce Clause of Article I of the Constitution to regulate both interstate and intrastate businesses, public as well as private, that affect thenation's commerce:
The national interest that Congress sought to promote in Title II was undoingracial discrimination. Racial discrimination, in turn, is a moral wrong thatthe Constitution authorizes Congress to regulate under the national police power, which is the authority to pass legislation that may restrict individualliberties in the interest of promoting the general welfare.
In 1881, the Supreme Court decided a set of cases collectively called the Civil Rights Cases, in which various provisions of the Civil Rights Act of 1875 outlawing discrimination in public accommodations were declared unconstitutional. In the Civil Rights Cases, the Court held that the Fourteenth Amendment, which granted citizenship rights to freed slaves and which wasthe basis for the Civil Rights Act of 1875, could not be enforced against private businesses. So when Congress next addressed the issue of racial discrimination, in 1964, it used its power under the Commerce Clause as the primaryauthority for the legislation.
The Commerce Clause proved to be a powerful tool for combatting racism. Although the appellant in Heart of Atlanta Motel claimed that its operationwas local, the Court found that the effects of its policies and practices reached far beyond Atlanta and even beyond the state border. In particular, byrefusing to provide rooms for African American travelers, many of whom came from out of state on business, the motel was affecting interstate commerce. InKatzenbach v. McClung, decided the same day, the Court used similar logic in applying the Civil Rights Act of 1964 to a small restaurant that purchased its supplies locally and served mostly local customers. Because some ofthe restaurant's supplies originally came from out of state, its activitieshad an impact on interstate commerce. Taken together, Heart of Atlanta Motel and Katzenbach v. McClung amply demonstrated that Congress hadthe means to combat racism in America.
Related Cases
Heart of Atlanta Motel, Inc.
Appellee
United States
Appellant's Claim
That provisions of the Civil Rights Act of 1964, requiring hotel and motel owners to provide accommodations to African Americans, cannot be enforced against privately owned public accommodations.
Chief Lawyer for Appellant
Moreton Rolleston, Jr.
Chief Lawyer for Appellee
Archibald Cox, U.S. Solicitor General
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark (writing for theCourt), William O. Douglas, Arthur Goldberg, John Marshall Harlan II, PotterStewart, Earl Warren, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
14 December 1964
Decision
By a unanimous decision, the Supreme Court upheld the public accommodations provisions of the Civil Rights Act of 1964.
Significance
Heart of Atlanta Motel marked a turning point in Congress' efforts topromote civil rights through use of its power to regulate interstate commerce.
The Heart of Atlanta Motel was a 216-room establishment located in downtown Atlanta, Georgia, close to several interstate highways. The motel advertised in national magazines and on billboards within Georgia. Approximately 75 percent of the motel's registered guests came from out of state.
In 1964, Congress passed a civil rights act intended to eliminate racial discrimination. Some of the act's most important provisions appeared in a sectionknown as Title II, which insured full access to places of public accommodation to racial minorities. Prior to passage of the act, the Heart of Atlanta Motel had consistently refused to supply African Americans with rooms. Claimingthat it was the motel's right as a private business to continue this practice, the motel operator filed suit in the U.S. District Court for the NorthernDistrict of Georgia, seeking a judicial declaration that Title II was unconstitutional, as well as an injunction preventing the enforcement of the publicaccommodations provisions.
The federal government countersued, seeking enforcement of the act against the hotel. The government prevailed in district court, and the hotel operatorsappealed this judgment to the U.S. Supreme Court.
Supreme Court Affirms Congressional Authority to Regulate Private Businessunder the Commerce Clause
Justice Clark, writing for a unanimous Court, upheld the power of Congress under the Commerce Clause of Article I of the Constitution to regulate both interstate and intrastate businesses, public as well as private, that affect thenation's commerce:
[T]he determinative test of the exercise of power by the Congress under the Commerce Clause is simply whether the activitysought to be regulated is "commerce which concerns more States than one" andhas a real and substantial relation to the national interest.
The national interest that Congress sought to promote in Title II was undoingracial discrimination. Racial discrimination, in turn, is a moral wrong thatthe Constitution authorizes Congress to regulate under the national police power, which is the authority to pass legislation that may restrict individualliberties in the interest of promoting the general welfare.
In 1881, the Supreme Court decided a set of cases collectively called the Civil Rights Cases, in which various provisions of the Civil Rights Act of 1875 outlawing discrimination in public accommodations were declared unconstitutional. In the Civil Rights Cases, the Court held that the Fourteenth Amendment, which granted citizenship rights to freed slaves and which wasthe basis for the Civil Rights Act of 1875, could not be enforced against private businesses. So when Congress next addressed the issue of racial discrimination, in 1964, it used its power under the Commerce Clause as the primaryauthority for the legislation.
The Commerce Clause proved to be a powerful tool for combatting racism. Although the appellant in Heart of Atlanta Motel claimed that its operationwas local, the Court found that the effects of its policies and practices reached far beyond Atlanta and even beyond the state border. In particular, byrefusing to provide rooms for African American travelers, many of whom came from out of state on business, the motel was affecting interstate commerce. InKatzenbach v. McClung, decided the same day, the Court used similar logic in applying the Civil Rights Act of 1964 to a small restaurant that purchased its supplies locally and served mostly local customers. Because some ofthe restaurant's supplies originally came from out of state, its activitieshad an impact on interstate commerce. Taken together, Heart of Atlanta Motel and Katzenbach v. McClung amply demonstrated that Congress hadthe means to combat racism in America.
Related Cases
- Hall v. DeCuir, 95 U.S. 485 (1878).
- Civil Rights Cases, 100 U.S. 3 (1887).
- Hoke v. United States, 227 U.S. 308 (1913).
- Caminetti v. United States, 242 U.S. 470 (1917).
- Katzenbach v. McClung, 379 U.S. 294 (1964).
- Griffin v. Maryland, 378 U.S. 130 (1971).
Further Readings
- Bell, Derrick A. Race, Racism, and American Law, 2nd ed. Boston, MA: Little, Brown, 1980.
- Wood, L. Ingleby. The Drive to Desegregate Places of Public Accommodation. New York: Garland, 1991.
- Nieman, Donald G., ed. Black Southerners and the Law, 1865-1900. New York, NY: Garland, 1994.
User Comments Add a comment…
2 months ago
what is the supreme courts decision on the heart of atlanta motel v. united states?