Heart of Atlanta Motel v. United States

1. Importance

1.1. Title II of the Civil Rights Act contains a specific exemption for private clubs or other establishments which are not open to the public. Many cases have considered whether particular organizations are in fact private within the meaning of this law. For example, courts have ruled that YMCAs were not private clubs and that their rental of rooms brought them within the public accommodations provisions of Title II.

1.2. 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 overt [direct] racial discrimination in public accommodations.

2. Influence

2.1. In Boy Scouts of America v. Dale, 2000, the Supreme Court considered whether New Jersey's public accommodations law could require the Boy Scouts to accept a gay man as an assistant scoutmaster. The Court found that the Boy Scouts is a private organization and ruled that a State may not require a private group to take actions or express points of view contrary to their own beliefs. New Jersey's public accommodations law infringed the Boy Scouts' freedom of expressive association and interfered with their right to oppose homosexual conduct.

2.2. In another 1964 case, Katzenbach v. McClung, the Court upheld the Civil Rights Act of 1964 even for a small local restaurant (Ollie's Barbeque). The Court held that even though the restaurant's customers were local, it bought much of its supplies through interstate commerce, and that was enough to bring it under the Commerce Clause.

3. Impact

3.1. President John F. Kennedy proposed the Civil Rights Act as a step toward ending discrimination based on race, color, religion, or national origin. President Lyndon B. Johnson eventually obtained passage of an even stronger version of the act. In addition to the provisions of Title II dealing with public accommodation at issue in Heart of Atlanta Motel, the Act also covers equal voting rights and discrimination by trade unions, schools, or employers, requires desegregation of public schools, and prohibits discrimination in the distribution of funds under federally assisted programs.

3.2. The exclusionary practices were found to be nationwide, not just in the South. The Secretary of Commerce testified that there is "no question that this discrimination in the North still exists" as well as the West and Midwest. This decision effected the entire country and targeted the roots of discrimination from multiplying.

4. Issue

4.1. Heart of Atlanta Hotel - felt it was unconstitutional for the federal government to dictate who private businesses serve.

4.2. The owner also claimed that the title violated the Fifth Amendment’s guarantees of due process and just compensation for the taking of private property because it deprived him of the right to choose his customers and that it violated the Thirteenth Amendment’s prohibition of involuntary servitude because it compelled him to rent rooms to blacks. The district court upheld the constitutionality of Title II and issued a permanent injunction requiring the motel to cease discriminating against black customers.

4.3. The Motel Owner argued that he was not engaged in interstate commerce and was a motel of "purely local character". The motel was accesible to state and interstate highways.

5. Facts

5.1. Heart of Atlanta Hotel - argued it was unconstitutional for the federal government to dictate who private businesses serve.

5.2. The Civil Rights Act of 1964 prohibited places of “public accommodation“ from discrimination based on customers' race, sex, color, religion, or national origin. The Heart of Atlanta Motel challenged the constitutionality of this provision and, after losing before a three-judge federal court, appealed to the Supreme Court.

5.3. Heart of Atlanta Motel had 216 rooms available to transient guests and had historically rented rooms only to white guests. Appellant solicits business from outside the State of Georgia through advertising in national travel magazines and other media. Approximately 70% of its guests are from outside the state. Appellant contends that Congress has overreached its authority under the Commerce Clause in enacting the Act.

6. Rule of law

6.1. Heart of Atlanta Motel was in violation of the Civil Rights Act of 1964.

6.2. The District Court Ruled that the Motel's action did violate the Constitution and prohibited the owner from discriminating based on race. The Owner appealed and the case ultimately went to the Supreme Court.

6.3. The district court upheld the constitutionality of Title II and issued a permanent injunction requiring the motel to cease discriminating against black customers.

6.4. Congress may regulate the ability of commercial institutions to deny service on the basis of race under its power to regulate interstate commerce.

7. Analysis / Application

7.1. The Supreme Court ruled that Congress had the power under the Commerce Clause to enact the prohibitions on discrimination contained in the public accommodations section of the Civil Rights Act of 1964. Justice Thomas Clark wrote the opinion for a unanimous Court. He reviewed testimony presented at congressional hearings showing that Americans had become increasingly mobile, but that African Americans were discriminated against by hotels and motels, and often had to travel longer distances to get lodging or had to call on friends to put them up overnight.

7.2. Justice Clark noted that under the Interstate Commerce Act, “…the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the States of origin and destination, which might have a substantial and harmful effect upon that commerce. One need only examine the evidence which we have discussed above to see that Congress may-as it has-prohibit racial discrimination by motels serving travelers, however 'local' their operations may appear.“

7.3. Justice Clark also found that the Act did not deprive the motel owner of liberty or property under the Fifth Amendment. Because Congress has the right to prohibit discrimination in accommodations under the Interstate Commerce Act, the motel “has no 'right' to select its guests as it sees fit, free from governmental regulation.“

8. Conclusion

8.1. The case was appealed to the Supreme Court, where oral arguments were heard on Oct. 5, 1964. In a unanimous (9–0) ruling issued on December 14, the court affirmed the district court’s finding. In his opinion for the court, Justice Tom C. Clark argued that the motel’s transactions clearly affected interstate commerce and thus fell within the purview of congressional regulation, and he rejected the petitioner’s arguments that the title violated the Fifth and Thirteenth amendments as misguided in point of both history and law.

8.2. The Supreme Court decision was unanimous. The Court upheld the law. Justice Tom Clark wrote for the Court. He pointed out that the Court had long upheld Congress's power to regulate interstate commerce under the Commerce Clause. One of the cases he cited was Gibbons v. Ogden, decided in 1824.Beginning with the New Deal in the 1930s, Congress often claimed authority to pass legislation under the Commerce Clause, and the Court generally upheld that power. In this case, Clark said that Congress could regulate both interstate commerce and activities within a state as part of its national "police power" to outlaw moral wrongs.