Heart of Atlanta Motel v. United States 1964
Heart of Atlanta Motel v. United States 1964
Appellant: Heart of Atlanta Motel, Inc.
Appellee: United States
Appellant's Claim: That Title II of the Civil Rights Act of 1964, requiring hotel and motel owners to provide accommodations to black Americans, cannot be enforced against privately owned establishments.
Chief Lawyer for Appellant: Moreton Rolleston, Jr.
Chief Lawyer for Appellee: Archibald Cox, U.S. Solicitor General
Justices Dissenting: None
Date of Decision: December 14, 1964
Decision: Ruled in favor of the United States by upholding Title II of the Civil Rights Act of 1964.
Significance: In the first major test of the landmark Civil Rights Act of 1964, the Court unanimously upheld the act. The decision greatly aided black Americans in their civil rights struggle. The Commerce Clause of the U.S. Constitution proved to be a powerful tool in the battle to end racial discrimination.
More often than not, black Americans in the early 1960s had to rely on rented rooms in private homes or the hospitality of friends if they were to travel far from their home. Hotels and motels dotted along highways and in towns provided comfortable accommodations for white Americans but black Americans had no access to these establishments.
Discrimination in Accommodations
The accommodation problem was recognized as early as the 1870s when Congress passed the Civil Rights Act of 1875. The act prohibited discrimination (giving privileges to one group, but not to another similar group) in facilities such as inns and theaters which were privately owned but commonly open to the public. Yet, in Civil Rights Cases (1883) the U.S. Supreme Court struck down the act. Saying that discrimination prohibitions applied only to government actions, the Court ruled the act could not apply to the discriminatory actions of private persons. The government remained powerless to stop discrimination by private persons for the next eighty years.
Decades of discrimination led to the civil rights movement of the 1950s and 1960s. Civil rights are a person's individual rights set by law. Black Americans, denied their civil rights, protested in the streets. Congress responded to the social unrest by passing comprehensive civil rights legislation, the Civil Rights Act of 1964. Title II of this act prohibited discrimination based on race, color religion, or national origin in public accommodations that were in any way involved in interstate commerce. Examples of public accommodations are privately owned inns, hotels, motels, and restaurants which are open to the general public. Interstate commerce means any business or trade carried on between different states. Inns, hotels, and motels do business with guests traveling between states by providing them lodging. Therefore, they are part of interstate commerce.
Article I, Section 8 of the Constitution, known as the Commerce Clause, grants Congress the power to regulate all interstate commerce. Does Congress have the power to regulate discriminatory practices by private individuals such as owners of motels that affect interstate commerce? It had tried to do just that with passage of Title II of the Civil Rights Act of 1964. The first case challenging the constitutionality of the landmark act reached the Supreme Court within the year.
The Heart of Atlanta Motel
The Heart of Atlanta Motel, located near interstate and state highways, had 216 rooms available to guests. The motel advertised extensively outside the state of Georgia through national media and magazines with national circulation. It also accepted convention trade from outside Georgia. Approximately 75 percent of its registered guests were from out of state. Before passage of the Civil Rights Act of 1964 the motel followed the common practice of refusing to rent rooms to black Americans. They fully intended to continue the practice. The motel's owner filed a lawsuit contending that Congress had exceeded its power under the Commerce Clause by passing Title II of the act to regulate local private businesses such as his hotel. Second, the owner claimed that the act violated "the Fifth Amendment because appellant [the owner] is deprived of the right to choose its customers and operate its business as it wishes, resulting in a taking of its liberty and property without due process of law." The Fifth Amendment says that no person shall be "deprived of life, liberty, or property, without due process of law."
The U.S. government countered by claiming the "unavailability to Negroes of adequate accommodations interferes significantly with interstate travel" hence interferes with interstate commerce. Therefore, under the Commerce Clause Congress had not exceeded its power and could regulate "such obstructions" to interstate commerce. Furthermore, the Fifth Amendment allows "reasonable regulation" and neither the appellant's liberty nor due process was violated.
The District Court upheld Title II of the act and ordered the motel owner to stop "refusing to accept Negroes as guests in the motel by reason of their race or color." The hotel operators appealed to the U.S. Supreme Court which agreed to hear the case.
The Civil Rights Act of 1964 Upheld
Writing for a unanimous (9-0) Court which found against Heart of Atlanta Motel, Justice Tom C. Clark delivered the decision upholding Title II of the Civil Rights Act of 1964. Justice Clark wrote that in researching Congress' debate over the Civil Rights Act of 1964 the evidence was clear the difficulties black Americans encountered in their attempts to find accommodations "had the effect of discouraging travel on the part of a substantial [large] portion of the Negro community." The evidence was "overwhelming . . . that discrimination by hotels and motels impedes [interferes with] interstate travel" and, therefore, obstructs interstate commerce. Justice Clark quoting from Caminetti v. United States (1917) wrote "the transportation of passengers in interstate commerce, it has long been settled, is within the regulatory powers of Congress, under the commerce clause of the constitution and the authority of Congress to keep the channels of interstate commerce free . . . is no longer open to question."
Next, Justice Clark wrote that not only did the Commerce Clause authorize Congress to regulate interstate commerce but allowed it to regulate activities within a state that had a "harmful effect" on interstate commerce. Because of its harmful effect on interstate commerce, "racial discrimination by motels serving travelers, however 'local' their operations may appear" could be regulated by Congress. Although the Heart of Atlanta Motel claimed its operation was local, the Court decided that the effects of its policies and practices reached far beyond Atlanta and the state border. Congress' regulation of racial discrimination in accommodations through Title II of the Civil Rights Act of 1964 was a constitutional approach which also contributed to correcting a "moral and social wrong."
Turning to the issue of whether or not the Fifth Amendment rights of the owner of Heart of Atlanta Motel had been violated by Title II, the Court rejected the charge. Justice Clark found "a long line of cases" where the Court had denied the claim that "prohibition of racial discrimination in public accommodations interferes with personal liberty."
A rticle I, Section 8, Clause 3 of the U.S. Constitution gives solely to Congress the power to regulate commerce between states and with foreign countries and Indian tribes. As used by the Constitution, the term commerce means all business or trade in any form between citizens. Interstate commerce is business between citizens across state lines. Sale and transportation of a product by persons in Florida to persons in Texas would be interstate commerce. In contrast, intrastate commerce is business conducted within one state only and subject to state control only.
The Commerce Clause empowers Congress to pass laws to regulate the flow of interstate commerce in order to keep interstate transactions free from local restrictions imposed by the states. If Congress finds that intrastate activities influence business between different states, it may regulate that area of intrastate commerce. For example, access to lodgings and restaurants located in each state allow persons to travel and do business from state to state. Therefore, they fall under interstate commerce regulation.
Other examples of federally regulated interstate commerce are transportation of goods between states and transmission of information across state lines by telephone, radio, television, or mail.
The Commerce Clause—A Powerful Tool
Heart of Atlanta Motel was the first legal challenge to the Civil Rights Act of 1964. The U.S. Supreme Court promptly and unanimously upheld the act. This outcome was far different than the decision in the Civil Rights Cases (1883) which left the Civil Rights Act of 1875 useless. The Commerce Clause became a powerful tool for combating racial discrimination. It gave Congress the constitutional backing to pass legislation promoting equal rights for black Americans. In a case decided the same day, Katzenbach v. McClung (1964), the Court reasoned in a similar manner as in Heart of Atlanta Motel. Katzenbach involved a small restaurant which did not serve blacks. Its customers were mostly local, but the restaurant did purchase some supplies which originally came from out of state. Because of the purchases of these supplies, the restaurant's activities were part of interstate commerce. Therefore, the government could regulate the restaurant and require it to serve blacks. Taken together, Heart of Atlanta Motel and Katzenbach demonstrated that Congress had found an effective constitutional pathway for combating racism in America.
Suggestions for further reading
Chideya, Farai. The Color of Our Future: Our Multiracial Future. New York: William Morrow & Co., 1999.
Griffin, John H. Black Like Me. New York: Signet, 1996.
Steinhorn, Leonard, and Barbara Diggs-Brown. By the Color of Our Skin. New York: E.P. Dutton, 1999.