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Heart of Atlanta Motel v. United States

Citation. 379 U.S. 241 (1964)
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Brief Fact Summary.

The Heart of Atlanta Motel refused to rent rooms to Black people in violation of Title II of the Civil Rights Act of 1964.

Synopsis of Rule of Law.

Congress can prohibit hotels and motels from racially discriminating against patrons pursuant to the Commerce Clause.  Title II of the Civil Rights Act of 1964 did not violate the Constitution.


Title II of the Civil Rights Act of 1964 prohibited certain places of public accomodation from discriminating by race. The Heart of Atlanta Motel refused to rent rooms to Black people, and intended to continue this practice.


Is Title II of the Civil Rights Act of 1964 unconstitutional?


No, Title II of the Civil Rights Act of 1964 is not unconstitutional.


The Supreme Court began its analysis by finding that the Civil Rights Cases were not relevent to the present case, because the law at issue in the Civil Rights Cases did not limit the affected businesses to those impinging on interstate commerce, and because the nature of interstate commerce had changed in the time between the Civil Rights Cases and the present case.

The Supreme Court then went on to cite congressional findings that showed that discrimination by hotels and motels impeded interstate travel by impeding Black people from traveling. The Supreme Court then found that the test of whether or not these obstructions empowered Congress to regulate this discrimination pursuant to the Commerce Clause was whether the regulated activity was commerce which concerns more than one state, and had a real and substantial relation to the national interest. According to the Supreme Court, the fact that Congress was regulating against a moral and social wrong did not make the regulation invalid, because there was still overwhelming evidence that racial discrimination disrupted commercial intercourse. The Supreme Court also held that whether the operation of the motel here was purely local did not matter, because Congress’ commerce power extended to local activities that might have a substantial and harmful effect upon interstate commerce.

Finally, the Supreme Court held that the Act did not deprive the plaintiff of liberty or property under the Fifth Amendment. According to the Supreme Court, the commerce power was a specific and pleneary power authorized by the Constitution, and Congress had a rational basis for finding that racial discrimination by motels affected commerce, and the means it selected to eliminate that discrimination were reasonable and appropriate. For these reasons, the Act did not violate the Fifth Amendment.

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