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Heart of Atlanta Motel v. United States

Heart of Atlanta Motel Inc. v. United States, et. al. 379 US 241(1964)


This important case represents an immediate challenge to the Civil Rights Act of 1964, the comprehensive landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for separate but equal treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans.

While during the mid-twentieth century, partly as a result of cases such as Powell v. Alabama 287 US 45 1932, Smith v. Allwright 321 US 649 1944, Shelley v. Kraemer 334 US 1 1948, Sweatt v. Painter 339 US 629 1950, McLaurin v. Oklahoma State Board of Regents 339 US 637 1950, NAACP v. Alabama 357 US 449 1958, Boynton v. Virginia 364 US 454 1960 and probably the most famous, Brown v. Board of Education of Topeka 347 US 483 1954, the tide against segregation and white supremacy began to turn, black Americans' fight for equal civil rights was far from over. In particular, the southern United States, where the Heart of Atlanta Motel was located, remained segregated even into the late 1960s.

The Case

Passed on 2 July 1964, the Civil Rights Act banned racial discrimination in public places, particularly in public accommodations, largely based on Congress' control of interstate commerce.

The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act violated his Fifth Amendment rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process of law and just compensation. Finally, the owner argued that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment rights.

In response, the United States countered that the restrictions in adequate accommodation for black Americans severely interfered with interstate travel, and that Congress, under the Constitution's Commerce clause, was certainly within its power to address such matters. Moreover, they argued, the Fifth Amendment does not forbid reasonable regulation of interstate commerce and such incidental damage did not constitute the "taking" of property without just compensation or due process of law. Third, they argued that the Thirteenth Amendment applied primarily to slavery and the removal of widespread disabilities associated with it; in such kind, the Amendment certainly would not place issues of racial discrimination in public accommodations beyond the reach of Federal and state law.

The District court ruled in favor of the United States and issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination in terms of the goods or services that it offered to guests or the general public upon its premises.

The Decision

Announced on 14 December 1964, the opinion of the court was delivered by Justice Tom C. Clark, with concurring opinions by Justice Arthur Goldberg, Justice Hugo Black, and Justice William O. Douglas.

The Court held that Congress acted well within its jurisdiction of the Interstate Commerce clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it hard to conceive that such an Amendment might possibly be applicable in restraining civil rights legislation. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out of state, and that it was strategically located near both Interstates 75 and 85 as well as two major U.S. Highways, the Court found that the business clearly affected interstate commerce. As such, it therefore upheld the permanent injunction issued by the District Court, and required the Heart of Atlanta Motel to receive business from clientele of all races.

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