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Heart of Atlanta Motel, Inc. v. United States

Citation. 22 Ill.379 U.S. 241, 85 S. Ct. 348, 13 L. Ed. 2d 258 (1964)
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Brief Fact Summary.

The owners of a motel refused to rent rooms to Negroes and wanted to continue to do so. The motel was situated between many interstates in Atlanta and 75% of its patronage was from out-of-town.

Synopsis of Rule of Law.

If a business activity deals with or affects interstate commerce, it is subject to the reach of the Commerce Clause.


A motel was situated in downtown Atlanta, close to many interstates. The motel also took out billboards and advertised nationally. The owners of the motel refused to serve Negroes, and challenged the constitutionality of Title II of the Civil Rights Act of 1964.


Title II of the Civil Rights Act of 1964 constitutional?


The motel could not refuse service to Negroes because Title II was not unconstitutional. Discrimination against Negroes keeps them from traveling in the country. Such discrimination may adversely affect commerce, thereby invoking the Commerce Clause. The motel was therefore subject to Congress’ power to regulate its actions by passing laws such as the Civil Rights Act.


The test of Congress’ power to regulate commerce is whether the activity at issue concerns more than one state and substantially affects national commerce.

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