Heart of Atlanta Motel, Inc. v. United States

This important case represented an immediate challenge to the Civil Rights Act of 1964, the 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. In the 100 years preceding 1964, African Americans in the United States had been subjected to racial segregation, a system of racial separation which, while in name providing for "separate but equal" treatment of both white and African Americans, in fact provided inferior accommodation, services, and treatment for African Americans. During the mid-20th century, partly as a result of cases such as Powell v. Alabama, 287 U.S. 45 (1932); Smith v. Allwright, 321 U.S. 649 (1944); Shelley v. Kraemer, 334 U.S. 1 (1948); Sweatt v. Painter, 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents, 339 U.S. 637 (1950); NAACP v. Alabama, 357 U.S. 449 (1958); Boynton v. Virginia, 364 U.S. 454 (1960); and, most notably, Brown v. Board of Education of Topeka, 347 U.S. 483 (1954), public opinion began to turn against segregation. Despite the outcomes of these cases, segregation remained in full effect into the 1960s in parts of the southern United States, where the Heart of Atlanta Motel was located. == Court case ==

Petitioner's argument The Heart of Atlanta Motel was a large, 216-room motel that opened on September 5, 1956 in Atlanta, Georgia. In direct violation of the terms of the Civil Rights Act of 1964, which banned racial discrimination in public places, largely based on Congress's control of interstate commerce, the motel refused to rent rooms to African-American patrons. The owner, Moreton Rolleston, filed suit in federal court, arguing that the requirements of the Act exceeded the authority the Commerce Clause granted to Congress over interstate commerce. Rolleston specifically argued against Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, religion, or national origin in places of public accommodation. Hotels and motels are included as types of public accommodation in the Act, and so are restaurants that serve food substantially to those who participate in interstate travel. In further arguing against the validity of the Act's basis on the Commerce Clause, he stated that people themselves are not commerce; rather, people engage in commerce. Therefore, a hotel or motel does not necessarily engage in interstate commerce because the profit comes from persons rather than goods. Rolleston also asserted that racial discrimination by an individual is not prohibited by the Fourteenth Amendment or the Constitution, claiming that discrimination is a private wrong that individuals are allowed to commit. The case was combined with the case of the future Governor of Georgia Lester Maddox, regarding his Pickrick restaurant and his refusal to serve African Americans. The plaintiffs appealed the decision to the U.S. Supreme Court, which unanimously upheld the District Court ruling. The opinion of the court, announced on December 14, 1964, was delivered by Justice Tom C. Clark, with concurring opinions by Justices Arthur Goldberg, Hugo Black, and William O. Douglas. The ruling held that Congress acted well within its authority under the 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 difficult to conceive that such an amendment might 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 Interstates 75 and 85 as well as two major Georgia highways, the Court found that the business clearly affected interstate commerce. Accordingly, it upheld the permanent injunction issued by the district court and required the Heart of Atlanta Motel to receive business from the clientele of all ethnicities. == Case legacy ==

Heart of Atlanta Motel, Inc. v. United States has been cited in at least 690 other case decisions since its ruling, including multiple other Supreme Court cases. In the 1997 case Camps Newfound/Owatonna, Inc. v. Town of Harrison a summer camp in Maine that mainly serviced out-of-state residents fought against a state tax exemption statute that favored organizations that serviced state residents. The courts compared out-of-state campers staying at a summer camp to out-of-state residents occupying a hotel, deeming the camp a participant in interstate commerce. Another example is the 1966 case United States v. Guest, in which the courts ruled, due to the conspiratorial murder of Lt. Col. Lemuel Penn while he was traveling home, that forcefully depriving someone's right to travel is unconstitutional. == See also ==