Heart of Atlanta Motel, Inc. v. United States

Argued: October 5, 1964
Decided: December 14, 1964
Full case name: Heart of Atlanta Motel, Incorporated v. United States, et al.

Holding: Congress did not unconstitutionally exceed its powers under the Commerce Clause by enacting Title II of the 1964 Civil Rights Act, which prohibited racial discrimination in public accommodations. Northern District of Georgia affirmed.

Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), was a landmark decision of the Supreme Court of the United States holding that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, religion, or national origin in public accommodations.

Background

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.

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.

In addition, Rolleston maintained that it 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, he contended that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to African Americans, thereby violating his Thirteenth Amendment rights. Rolleston noted that in 1944 the Fifth Circuit Court of Appeals for the United States held that even if acts committed in involuntary servitude are compensated, it still violates the Thirteenth Amendment.

Rolleston maintained throughout his argument that the Constitution should be interpreted as it was at the time of its creation and as the Framers originally intended it. He concluded his opening argument by stating that the Supreme Court did not need to exist if the Commerce Clause allowed for Congress to enact any regulations it pleases.

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