Heart of Atlanta Motel, Inc. v. United States

Citation. 379 U.S. 241, 85 S.Ct 348, 13 L.Ed.2d 258 (1964).

Brief Fact Summary.

The Heart of Atlanta Motel sought a judgment declaring Title II of the Civil Rights Act of 1964 unconstitutional so it could continue refusing to rent rooms to Black guests.

Synopsis of Rule of Law.

Congress can remedy “moral and social” wrongs through its Commerce Clause powers so long as the regulated activity concerns multiple states and “has a real and substantial relation to the national interest.”

Facts.

The Heart of Atlanta Motel had a policy of refusing Black guests.  Despite Title II of the Civil Rights Act of 1964 prohibiting this discriminatory behavior, the Motel sought to continue acting under its policy.  The Motel alleged that the Act was unconstitutional as applied to the Motel because it was “of a purely local character,” only operating within Georgia.  The Motel, however, advertised in national magazines, had over 50 billboards within the state, and approximately 75% of its guests were from outside of Georgia.

Issue.

Whether Title II of the Civil Rights Act of 1964 was unconstitutional .

Held.

JUSTICE CLARK holding:  No.  Title II of the Act was validly enacted under the Commerce Clause.  In deciding whether Congress acted within its bounds under the Commerce Clause, courts must ask “whether the activity sought to be regulated is commerce which concerns more States than one and has a real and substantial relation to the national interest.”  Because the Motel served interstate guests and racial discrimination impacts interstate commerce, Title II was within Congress’ powers under the Commerce Clause.

Discussion.

Justice Clark reasoned that this law was not invalid because it sought to remedy “moral and social wrong[s].”  Congress had earlier used its powers under the Commerce Clause to regulate gambling and racial discrimination, so the fact that Title II was enacted to remedy discrimination was immaterial.  Here, there was evidence that discrimination made it harder for Black people to find places to stay while traveling, thus making it harder for them to travel.  Citing Gibbons v. Ogden, the Court reasoned that the Commerce Clause grants Congress the power to regulate transportation, regardless of “whether the transportation is commercial in character.”  Because Black people might be deterred from traveling because they might not be able to find a place to stay, it did not matter how “local the operation” of the Motel was.