Heart of Atlanta Motel, Inc. v. United States

Following is the case brief for Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964).

Case Summary of Heart of Atlanta Motel, Inc. v. United States:

  • A large motel in Atlanta refused to serve African Americans.  The Civil Rights Act of 1964 prohibits racial discrimination in places of public accommodation
  • The motel owner challenged the Civil Rights Act in Federal District Court, and the Government counterclaimed, seeking to enforce the Act against the motel.
  • The District Court held that the Civil Rights Act is constitutional, and that the motel could not refuse to serve African American patrons.
  • The Supreme Court affirmed the District Court’s decision.  It held that the Commerce Clause gives Congress the authority to mandate that private businesses that serve the public cannot discriminate based on race.

Heart of Atlanta Motel, Inc. v. United States Case Brief

Statement of the Facts:

The Heart of Atlanta Motel is a large motel in Atlanta, Georgia, that gets approximately 75% of its business from interstate travelers.  The owner of the Motel refused to provide rooms to African Americans.  Because he wished to continue to discriminate against African Americans, the owner of the Motel challenged the Civil Rights Act of 1964, which prohibits racial discrimination in places of public accommodation.

Procedural History:

  • The Motel owner sued in Federal District Court, arguing that Congress exceeded its Commerce Clause and other powers in enacting the Civil Rights Act.
  • The Government counterclaimed against the Motel owner to stop him from refusing to provide rooms to African Americans.
  • A three-judge panel of the District Court for the Northern District of Georgia upheld the constitutionality of the Civil Rights Act, and enjoined the Motel owner from discriminating against African American patrons.
  • The Supreme Court agreed to hear the case.

Issue and Holding:

Was the Civil Rights Act of 1964, which prohibits discrimination in places of public accommodation, a proper exercise of Congress’s Commerce Clause authority?  Yes.

Judgment:

The judgment of the District Court for the Northern District of Georgia is affirmed.

Rule of Law or Legal Principle Applied:

Congress can use the Commerce Clause to mandate that private businesses follow the Civil Rights Act of 1964, which bans racial discrimination in places of public accommodation.

Reasoning:

  • The Commerce Clause gives Congress authority in this case.

A century of Commerce Clause jurisprudence demonstrates that prohibiting discrimination by public businesses, in accordance with Title II of the Civil Rights Act of 1964, was well within Congress’s Commerce authority.  The movement of persons between the States is “commerce,” and racial discrimination has a disruptive effect on that interstate commerce.  Simply because the Civil Rights Act was passed to correct a moral wrong in society does not change the analysis. Depriving one race of access to public lodging has a substantial impact on interstate commerce.

  • The Motel owner’s other constitutional arguments are unavailing.

With regard to the Motel owner’s other arguments, the Act mandating equal access to public businesses is not a “taking” under the Fifth Amendment.  Also, the notion that business owners would invoke the Thirteenth Amendment “involuntary servitude” language that ended slavery in order to discriminate against African Americans is not worthy of consideration.

  • The Court need not consider grounds other than the Commerce Clause.

The Court noted that the Fourteenth Amendment may also be grounds upon which to affirm the lower court’s judgment.  Yet, finding Congress’s authority under the Commerce Clause will suffice.

Concurring Opinion (Black):

This case involved another matter regarding a barbecue restaurant in Alabama, whose owner also refused to serve African Americans.  The Commerce Clause along with the Necessary and Proper Clause provides support to reach intrastate activity that affects interstate commerce.  Thus, the Act is enforceable against both the Heart of Atlanta Motel and the barbecue restaurant.

Concurring Opinion (Douglas):

While the Commerce Clause applies in this case, the decision to rid the nation of racial discrimination should be found in a constitutional principle that deals with more than the interstate movement of cattle, fruit, and steel.

Rather, the Court should have found support for its decision in section 5 of the Fourteenth Amendment, which gives Congress the authority to enact laws to enforce the Equal Protection Clause.  Using that as the Constitutional basis would obviate an analysis of whether a particular private business affects, or does not affect, interstate commerce.

Concurring Opinion (Goldberg):

The Civil Rights Act of 1964 appears to be using the Fourteenth Amendment as its primary source of constitutional authority, not the Commerce Clause.

Significance:

Heart of Atlanta Motel, Inc. v. United States is a landmark decision.  It established the principle that private businesses can be forced to abide by the Civil Rights Act of 1964.  It dealt a serious blow to the structure of segregation that the Civil Rights Act was enacted to combat.

Student Resources:

https://supreme.justia.com/cases/federal/us/379/241/case.html

https://www.oyez.org/cases/1964/515

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