Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964)
The Commerce Clause extends the anti-discrimination provisions in the Civil Rights Act of 1964 to hotels that host travelers from outside the state.
A large motel in Atlanta refused to offer any of its 216 rooms to African-Americans even after the Civil Rights Act of 1964 explicitly banned this practice by prohibiting racial discrimination in public places. Bringing a challenge to the constitutionality of the law under the Commerce Clause, motel owner Moreton Rolleston argued that this clause did not give Congress the power to enact such a sweeping law. He believed that he had the right as the owner of a business property to have control over operating his business, including the types of customers whom he would serve. There was also a more minor claim under the Thirteenth Amendment in which Rolleston asserted that he was subjected to involuntary servitude by being forced to rent parts of his property (motel rooms) to people whom he did not choose (African-Americans).
Justifying the law, the government stated that the Commerce Clause grants Congress broad authority over the channels and instrumentalities of interstate travel, which include motels. It interpreted the Thirteenth Amendment as being tied to the eradication of slavery and related social mechanisms, and it asserted that forcing Rolleston to offer motel rooms to African-Americans was not an unjusitfied taking of property.
The court reviewed Rolleston's claim in conjunction with a similar case involving a restaurant run by future Georgia Governor Lester Maddox, who also refused to serve African-Americans.
- Tom C. Clark (Author)
- Earl Warren
- William Orville Douglas
- John Marshall Harlan II
- William Joseph Brennan, Jr.
- Potter Stewart
- Byron Raymond White
- Arthur Joseph Goldberg
The majority essentially agreed with all of the government's arguments in an opinion signed by all but one of the Justices. Clark and his peers were somewhat incredulous that Rolleston attempted to use the Thirteenth Amendment to pursue a discriminatory objective, considering that it was implemented to fight discrimination. The Court also was easily persuaded that the Commerce Clause justified Congress in regulating the motel's operations, since it was positioned near Interstates 75 and 85 and received most of its business from outside Georgia. This showed that it had an impact on interstate commerce, which is all that is needed to justify Congress in exercising the Commerce Clause power. The Court thus upheld the permanent injunction in one of the less contested of its landmark decisions.
- Hugo Lafayette Black (Author)
- William Orville Douglas (Author)
- Arthur Joseph Goldberg (Author)
During this era of Commerce Clause jurisprudence, actions by the federal government under this power were upheld if they regulated an activity that affected more than one state and had a substantial overall effect on national commerce. Although this case was important and influential, coming early in the Civil Rights era, the arguments that Rolleston advanced were so dubious at face value that the outcome was never seriously in doubt.
U.S. Supreme CourtHeart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964)
Heart of Atlanta Motel, Inc. v. United States
Argued October 5, 1964
Decided December 14, 1964
379 U.S. 241
Appellant, the owner of a large motel in Atlanta, Georgia, which restricts its clientele to white persons, three-fourths of whom are transient interstate travelers, sued for declaratory relief and to enjoin enforcement of the Civil Rights Act of 1964, contending that the prohibition of racial discrimination in places of public accommodation affecting commerce exceeded Congress' powers under the Commerce Clause and violated other parts of the Constitution. A three-judge District Court upheld the constitutionality of Title II, §§ 201(a), (b)(1) and (c)(1), the provisions attacked, and, on appellees' counterclaim, permanently enjoined appellant from refusing to accommodate Negro guests for racial reasons.
1. Title II of the Civil Rights Act of 1964 is a valid exercise of Congress' power under the Commerce Clause as applied to a place of public accommodation serving interstate travelers. Civil Right Cases, 109 U. S. 3, distinguished. Pp. 379 U. S. 249-262.
(a) The interstate movement of persons is "commerce" which concerns more than one State. Pp. 379 U. S. 255-256.
(b) The protection of interstate commerce is within the regulatory power of Congress under the Commerce Clause whether or not the transportation of persons between States is "commercial." P. 379 U. S. 256.
(c) Congress' action in removing the disruptive effect which it found racial discrimination has on interstate travel is not invalidated because Congress was also legislating against what it considered to be moral wrongs. P. 379 U. S. 257.
(d) Congress had power to enact appropriate legislation with regard to a place of public accommodation such as appellant's motel even if it is assumed to be of a purely "local" character, as Congress' power over interstate commerce extends to the regulation of local incidents thereof which might have a substantial and harmful effect upon that commerce. P. 379 U. S. 258.
(2) The prohibition in Title II of racial discrimination in public accommodations affecting commerce does not violate the Fifth
Amendment as being a deprivation of property or liberty without due process of law. Pp. 379 U. S. 258-261.
(3) Such prohibition does not violate he Thirteenth Amendment as being "involuntary servitude." P. 379 U.S. 261.
231 F. Supp. 393, affirmed.