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Heart of Atlanta Motel, Inc. v. United States

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Brief Fact Summary.

The appellant challenged the constitutionality of Title II of the Civil Rights Act of 1964 alleging that Congress exceeded its power to regulate commerce when it passed the Act that prohibits business establishments, from discriminating guests on the basis of color or race, if those establishments affect commerce.

Synopsis of Rule of Law.

The power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the states of origin and destination, which might have a substantial and harmful effect upon that commerce.

Points of Law - Legal Principles in this Case for Law Students.

In this connection Justice DOUGLAS stated that the right of persons to move freely occupies a more protected position in our constitutional system than does the movement of cattle, fruit, steel and coal.

View Full Point of Law
Facts.

The appellant owns and operates the Heart of Atlanta Motel that provides rooms to transient guests. It is readily accessible to interstate highways and state highways. Appellant solicits patronage from outside the State of Georgia through various national advertising media and maintains over 50 billboards and highway signs within the State. It accepts convention trade from outside Georgia and more than 75% of its registered guests are from out of State. The motel, however, had refused to rent rooms to Blacks and intended to continue its practice. Congress passed the Civil Rights Act of 1964 to restrain business establishments that serve the public and are a place of public accommodation from discriminating based on race or color if their operations affect commerce.

Issue.

May Congress prohibit the hotel from discriminating on the basis of race pursuant to the Civil Rights Act of 1964 that prohibits business establishments from discriminating based on race or color if their operations affect commerce?

Held.

Yes, Congress has the power to regulate the conduct of the hotel because its power to regulate interstate commerce includes the power to regulate the local incidents, including local activities in both the states of origin and destination, which might have a substantial and harmful effect upon that commerce. Voluminous testimony presents overwhelming evidence that discrimination by hotels and motels impedes interstate travel.

Concurrence.

Justice Black

The operations of the motel had adverse effect on commerce, prohibited by the Constitution. While the choice of policy is within the exclusive power of Congress, whether particular operations affect interstate commerce sufficiently to come under the constitutional power of Congress to regulate them is ultimately a judicial rather than a legislative question.

Discussion.

The action of the Congress in the adoption of the Act as applied here to a motel which concededly serves interstate travelers is within the power granted to it by the Commerce Clause of the Constitution. It may be argued that Congress could have pursued other methods to eliminate the obstructions it found in interstate commerce caused by racial discrimination. However, this is a matter of policy that rests entirely with the Congress not with the courts. How obstructions in commerce may be removed and what means are to be employed is within the sound and exclusive discretion of the Congress. The means chosen by Congress must be only be reasonably adopted to the end permitted by the Constitution and that is the case here. However local their operations might be, Congress may prohibit racial discrimination by motels serving travelers because motels’ operations affect the interstate commerce.


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