Heart of Atlanta Motel v.United States 379 U.S. 241 (1964)

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Heart of Atlanta Motel v.United States 379 U.S. 241 (1964) by Mind Map: Heart of Atlanta Motel v.United States 379 U.S. 241 (1964)


1.1. The owner of The Heart of Atlanta Motel , Moreton Rolleston, refused to rent rooms to African Americans which presented an immediate challenge to the Civil Rights Act of 1964. The motel was accessible to state and interstate highways. Mr. Rolleston advertised nationally with billboards throughout the state. Seventy-five percent of the guests were residents of other states. Civil rights Act of 1964 prohibits discrimination on the basis of race in any place of public accommodation. A place of public accommodation was defined to include motels and restaurants if that substantially affect interstate commerce.

2. Issue:

2.1. Moreton Rolleston, filed a suit in federal court stating his Fifth and Thirteenth Amendment rights were violated. He felt the Civil Rights Act was unconstitutional on the ground that Congress exceeded its constitutional authority to regulate commerce by enacting the statute. On direct appeal, the issue was if congress can prohibit racial discrimination in places of public accommodation by using its Commerce Clause authority.

3. Rule Of Law

3.1. The Fifth Amendment protects citizens from unjust deprivation of property without due process of law and just compensation. The Thirteenth Amendment primary applies to slavery and involuntary servitude except as punishment for a crime. The Commerce Clause permits the national government to legislate in areas in which Congress has not explicitly been granted power.

4. Analysis/Application

4.1. Plantiff

4.1.1. The plaintiff stated that congress had exceed its constitutional authority by enacting the Civil Rights Act. The motel alleged that it violated its due process rights to select its customers and operate it’s business as it wished.

4.2. Defendant

4.2.1. The foundation of the defense was if commerce can be used to protect civil rights.

4.3. Court

4.3.1. District Court up held the Civil Right as Constitutional. On direct appeal, Justice Clark stated The Civil Rights Acts is a valid exercise of Congress’s commerce clause as applied to places of public accommodation that serve interstate travelers. Congress’s power to regulate interstate commerce can regulate local incidents of commerce that have a substantial relation to the interstate flow of goods. Congress has the power to remove local obstructions to interstate commerce. Racial discrimination has a disruptive effect on interstate travel by substantially discouraging travel by African Americans. Justice Black in a concurring opinion stated that the motel’s racial discrimination polices have a great impact on interstate commerce, noting that there was extensive advertising on interstate highways. Justice Black also stated the act did not violate the motel’s due process rights as it did not regulate the use of private property. Furthermore he used the Fourteenth amendment to state that he could not take away congress’s power to protect African Americans from further discrimination. Justice Douglas in a concurring opinion stated that the impact on interstate commerce shouldn’t be a prerequisite for receiving protection against discrimination. He stated that in the Fourteenth Amendment there was protection of all persons in equal protection from the law. Justice Goldberg felt the opinion should be on both the fourteenth Amendment and the Commerce Clause, under bother provisions the Civil Rights Act could be enacted.

5. Conclusion

5.1. The Act did not violate the Constitution. The court’s holdings on Rolleston’s claim that the law violated his 5th and 13th amendments stated he neither had involuntary servitude or deprive him of property because he was receiving financial compensation for his rooms. The owner was prohibited from discriminating on the basis of race. The appeal in the United States Supreme Court upheld the Civil Rights Act of 1964. Local discriminatory practices could be halted by the power of Congress to regulate interstate commerce. A permanent injunction required the Heart of Atlanta Motel to refrain from racial discrimination when providing services or goods to guests or the general public on its premises. This was a landmark decision that allowed Congress to use its Commerce Clause powers to combat racial discrimination.

6. Impact

6.1. Florida ex rel. Attny. Gen vs. U.S. Dept. of Health and Human services Patient Protection and Affordable Care Act’s individual mandate exceed boundaries of Congress’s enumerated power under commerce clause

6.2. U.S. v Morrison (2000). The court overturned VAWA because the rule said it was unconstitutional under section 5 under the Fourteenth Amendment, where it says “no state shall…” The State Action Doctine was upheld in The Heart of Atlanta Motel v United States, the Court could not uphold the VAWA.

7. Importance

7.1. As a business professional it is important that the business and those employed by the business understand that they are prohibited by discrimination based on race, color, national origin, religion, or gender in all public accommodations. If for example you run a business of a huge chain of hotels it is critical to educate all employees on the prohibition of discrimination.

8. Infleunce

8.1. A business such as a restaurant that is along an interstate would not be permitted to discriminate on race or gender based on commerce clause. The private business would need to abide by Title II of the Civil Rights Acts of 1964.

8.2. Any place of entertainment along an interstate would need to provide accommodations not based on race, color, national origin, religion, or gender.