Heart of Atlanta Motel, Inc. v. United States

Facts of the case

Title II of the Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce. The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans. The government sought to enjoin the motel from discriminating on the basis of race under Title II.

Question

Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving places of public accommodation of the right to choose their own customers?

Conclusion

The Commerce Clause extends the anti-discrimination provisions in the Civil Rights Act of 1964 to hotels that host travelers from outside the state.

In a unanimous decision authored by Justice Clark, the Court held the government could enjoin the motel from discriminating on the basis of race under the Commerce Clause. Since the motel was positioned near Interstates 75 and 85 and received most of its business from outside Georgia, this showed that it had an impact on interstate commerce, which is all that is needed to justify Congress in exercising the Commerce Clause power.

Supreme Court of the United States

379 U.S. 241, 13 L. Ed. 2d 258, 85 S. Ct. 348, 1964 U.S. LEXIS 2187, SCDB 1964-017

No. 515

1964-12-14

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