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

1. Facts

1.1. Parties

1.1.1. Appellant: The owner of Heart of Atlanta - large motel in Atlanta, Georgia

1.1.2. Appellee: United States

1.2. What Happened

1.2.1. Appellant owns and operates the Heart of Atlanta Motel which has 216 rooms available for transient guests

1.2.2. The motel is readily accessible to the interstate highway

1.2.3. Motel seeks patronage and advertises nationally

1.2.4. Approximately 75% of guests are out fo state

1.2.5. Prior to passage of the Civil Rights Act of 1964, the Motel restricted its rent of rooms to white persons

1.2.6. After the passage of the Act it intended to continue this practice

1.3. Procedural History

1.3.1. The law suit was filed in a federal district court by the appellant in an effort to perpetuate the policy of not renting rooms to Negros

1.3.2. The owner of the motel asserts that Congress overstepped its constitutional authority to regulate commerce in passing of the Civil Rights Act.

1.3.3. The District Court sustained the constitutionality of all the sections of the Act under attack and issued a permanent injunction on the counterclaim of the appellees.

1.3.4. The Court restricted the appellant from refusing to rent rooms or refuse any services to Negroes on the basis of race.

1.3.5. The decision was affirmed on appeal and the case ultimately went to the United States Supreme Court.

2. Rule of Law

2.1. Title II of the Civil Rights Act of 1964 protects against discrimination based on race, color, religion, or national origin.

2.1.1. Any establishment that affects commerce is covered by the Title II of the Civil Rights Act. This includes “any inn, hotel, motel, or other establishment which provides lodging to transient guests…”

2.2. Congress based the Act on the Fourteenth Amendment as well as its power to regulate interstate commerce in accordance with Article 1 Clause 3 (Commerce Clause) of the Constitution of the United States

2.2.1. Commerce Clause allows Congress to regulate "commerce with foreign nations, and among the several states, and with Indian tribes"

3. Analysis

3.1. Plaintiff's Interpretation

3.1.1. Congress, in passing of the Civil Rights Act overstepped its constitutional authority to regulate commerce under Article 1, Clause 3 of the Constitution of the United States as applied to Heart of Atlanta motel because the motel was not engaged in the interstate commerce

3.1.2. The Act violates Fifth Amendment because in depriving appellant of the right to operate its business and choose his customers as he desires, it takes away its liberty and property without due process of law or just compensation

3.1.3. The Act violates the Thirteenth Amendment because Congress is subjecting the appellant to involuntary servitude by requiring him to rent rooms to Negroes against its will

3.2. Defendant's Interpretation

3.2.1. Unavailability of adequate accommodations to Negroes affects commerce by interfering with interstate travel

3.2.2. Congress, under the Commerce Clause has power to remove any obstruction to interstate commerce

3.2.3. Fifth Amendment does not prohibit reasonable regulation, and consequent damage does not constitute a “taking” as meant in the Fifth Amendment

3.2.4. The claim that the Act violates the Thirteenth Amendment fails because it is frivolous to suggest that the amendment directed to the abolition of slavery and widespread disabilities associated with it, places discrimination in public accommodations beyond the reach of both federal and state law

3.3. Court's Interpretation

3.3.1. Title II of the Civil Rights Act of 1964 is a valid exercise of Congress’ power under the Commerce Clause as applied to public accommodation with respect to interstate travel

3.3.1.1. The interstate movement concerns more than one state, and, thus is considered to be “commerce”

3.3.1.2. The protection of interstate commerce is within regulatory power of Congress under the Commerce Clause

3.3.1.3. Congress action in removing the disruptive effect of racial discrimination on interstate travel is not invalidated because Congress was also legislating against what it considered to be moral wrongs

3.3.1.4. Congress had power to legislate against business of purely “local” character since it might have a substantial and harmful effect upon commerce

3.3.2. The prohibition of racial discrimination in public accommodations affecting commerce does not constitute a deprivation of property or liberty without due process of law, and, thus, does not violate the Fifth Amendment

3.3.3. The prohibition does not constitute an “involuntary servitude” and, therefore, does not violate the Thirteenth Amendment.

4. Issue

4.1. The constitutionality of the Equal Protection Clause of the Civil Rights Act of 1964 with respect to Congress using its authority to regulate commerce under the Commerce Clause of the United States Constitution as applied to the local motel

4.2. Did Congress violate the Fifth and Fourteenth Amendments by forcing the owner of the hotel to abide by the Civil Rights Act of 1964?

5. Conclusion

5.1. The United State Supreme Court ruled that Congress was within its jurisdiction in passing the Civil Rights Act of 1964

5.2. The Commerce Clause gives authority to Congress to regulate even local private business when their activity affects interstate commerce

5.3. Herat of Atlanta must comply with the law and cease its discriminatory practices with regards to race

6. Impact

6.1. The case was cited in multiple subsequent cases that concerned application of the Commerce Clause to the power of Congress to regulate various activities

6.1.1. In United States v. Lopez – the Supreme court decided that in Gun-Free School Zone Act of 1990 Congress overstepped its authority to use the Commerce Clause to apply locally. In upholding the lower appellate court decision, the Supreme Court cited Heart of Atlanta case as one of the landmark decisions that played a role in their three-prong test. The first two prongs were not considered to be controversial, but Supreme Court by 5:4 majority ruled that the interstate commerce in this case was not substantial enough limiting the power of Congress to apply the Commerce Clause. United States v. Lopez, 514 U.S. 549 (1995)

6.1.2. In Gonzales v. Raich the United States Supreme Court decided that Congress had the authority to apply the Commerce Clause in banning marijuana use (superseding California’s Compassionate Use Act) citing Heart of Atlanta as one of the supporting cases. The Court determined that because growing marijuana even locally is an economic activity which clearly affects interstate commerce via drug trade and criminal activity (similar to how operations of local motel in Atlanta affects interstate commerce). Gonzales v. Raich, 545 U.S. 1, 125 (2005)

7. Importance

7.1. The case modified the rule of law by determining that under the Commerce Clause Congress can remove obstruction to interstate commerce caused by racial discrimination

7.2. The United States Supreme Court essentially unanimously affirmed the Civil Rights Act of 1964. If they would have invalidated even parts of it, the United States could have been a completely different country. It would be up to the states then to pass laws that make discrimination based on race illegal. Without guidance of the Supreme Court or authority of US Congress, it is not clear that some states would have passed such laws, making racial discrimination legal in those states

8. Influence

8.1. Multiple business practices have been instantly affected by the holding of the case, and the business landscape is entirely different today than it would of been if the case was decided differently

8.1.1. Modern healthcare is affected by the holding in many ways. First, no hospital or medical institution can deny medical care on the basis of race or color. Second, modern administration of the Affordable Care Act is affected by Courts decision in 2012 not to apply the Commerce Clause to uphold the Act (but rather uphold it on the basis of the power of Congress to administer taxes)

8.1.2. Current practice of any travel accommodation forbidding discrimination on the basis of race or color, takes its roots in the Heart of Atlanta holding