Heart of Atlanta Motel v. United States

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