Heart of Atlanta Motel,Inc. v. United States,1964

HEART OF ATLANTA MOTEL, INC. v. UNITED STATES,1964

HEART OF ATLANTA MOTEL, INC.

• The Heart of Atlanta Motel, located near interstate and state highways, had 216 rooms available to guests.

• Approximately 75 percent of its registered guests were from out of state.

• The motel advertised extensively outside the state of Georgia through national media and magazines with national circulation.

• The motel's owner filed a lawsuit contending that Congress had exceeded its power under the Commerce Clause by passing Title II of the act to regulate local private businesses such as his hotel.

• Second, the owner claimed that the act violated the Fifth Amendment because appellant,the owner, is deprived of the right to choose its customers and operate its business as it wishes, resulting in a taking of its liberty and property without due process of law.

• The Fifth Amendment says that no person shall be "deprived of life, liberty, or property, without due process of law.

• Before passage of the Civil Rights Act of 1964 the motel followed the common practice of refusing to rent rooms to black Americans.

UNITED STATES

• In 1964, Congress passed the Civil Rights Act.

• Title II of the Civil Rights Act of 1964 forbids racial discrimination by places of public accommodation such as hotels and restaurants.

Congress passed the Civil Rights Act of 1964 in response to ongoing discrimination against African-Americans, despite US Supreme Court rulings declaring these practices unconstitutional. The Eisenhower administration had little interest in protecting African-Americans' civil rights, so many parts of the country (especially the South) ignored the Supreme Court and continued operating under Jim Crow conditions. Both the Kennedy and Johnson administrations made civil rights and constitutional protection a higher priority, resulting in enforceable legislation like the Civil Rights Act of 1964.

Many businesses fought integration, or simply didn't want to serve African-American clients. They wanted to continue their racist practices without interference from the government, and a few directly challenged Congress' right to enact anti-discrimination legislation in court.

Heart of Atlanta Motel v. United States, 379 US 241 (1964) was a landmark case in which the owner of an Atlanta motel argued Title II of the Civil Rights Act of 1964, which prohibited public accommodations from discriminating against patrons on the basis of race, violated his constitutional rights.

• The US Supreme Court upheld Congress' right to regulate businesses under the Article I Interstate Commerce Clause. Several justices also noted the legislation could have enacted under the Fourteenth Amendment.

• Heart of Atlanta appealed to the United States Supreme Court.The U.S. Supreme Court agreed to hear the case.

• The US government argued that the travel of African Americans between states was impacted by their inability to stay in public accommodations.

• Writing for a unanimous (9-0) Court which found against Heart of Atlanta Motel, Justice Tom C. Clark delivered the decision upholding Title II of the Civil Rights Act of 1964.
• The District Court upheld Title II of the Civil Rights Act of 1964 as constitutional and ordered the motel owner to stop refusing to accept African Americans as guests in the motel by reason of their race or color.

Majority Opinion:

Justice Clark wrote that not only did the Commerce Clause authorize Congress to regulate interstate commerce but allowed it to regulate activities within a state that had a "harmful effect" on interstate commerce. Because of its harmful effect on interstate commerce, "racial discrimination by motels serving travelers, however 'local' their operations may appear" could be regulated by Congress. Although the Heart of Atlanta Motel claimed its operation was local, the Court decided that the effects of its policies and practices reached far beyond Atlanta and the state border. Congress' regulation of racial discrimination in accommodations through Title II of the Civil Rights Act of 1964 was a constitutional approach which also contributed to correcting a "moral and social wrong."

Turning to the issue of whether or not the Fifth Amendment rights of the owner of Heart of Atlanta Motel had been violated by Title II, the Court rejected the charge. Justice Clark found "a long line of cases" where the Court had denied the claim that "prohibition of racial discrimination in public accommodations interferes with personal liberty."

• The U.S. government countered by claiming the "unavailability to African Americans of adequate accommodations interferes significantly with interstate travel" hence interferes with interstate commerce. Therefore, under the Commerce Clause Congress had not exceeded its power and could regulate "such obstructions" to interstate commerce. Furthermore, the Fifth Amendment allows "reasonable regulation" and neither the appellant's liberty nor due process was violated.

The impact of the case on American society:

With the law upheld, a very powerful legal tool was available to enforce equal treatment. Over the years, there have been fewer and fewer instances of direct racial discrimination in public accommodations.

Juana O. Calderon

AP Government

4th Period

• Heart of Atlanta Motel,Inc. v. United States,1964 happened during the civil rights movement.