Heart of Atlanta Motel, Inc. v. United States
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Title II of the Civil Rights Act of 1964 forbids discrimination by places of public accommodation. The Heart of Atlanta Motel was charged with violating Title II for refusing to accept black people as guests.
The motel appealed its conviction all the way to the Supreme Court, arguing that the Civil Rights Act was an invalid exercise of Congressional power. The Court disagreed, saying that the Commerce Clause gave Congress the right to regulate interstate commerce and interstate activities. The Court explained that Title II was "carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people." The Court said that places like Heart of Atlanta Motel had no right to select guests as they saw fit, free from governmental regulation.
That same year, the Court also decided Katzenback v. McClung, which is the Courts most expansive reading of Congressional power under the Commerce Clause. In that case, the Court held that Congress could regulate the racially discriminatory seating practices at Ollies Barbeque, a small restaurant that bought all of its food locally and that served local customers. The Court said that Ollies fell under Congressional power because some of the food it purchased from its local supplier actually originated from out of state.
379 U.S. 241 (1964)
APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA
appellant, the owner of a large motel in Atlanta, Georgia, which restricts its clientele to white persons, three-fourths of whom are transient interstate travelers, sued for declaratory relief and to enjoin enforcement of the Civil Rights Act of 1964, contending that the prohibition of racial discrimination in places of public accommodation affecting commerce exceeded Congress' powers under the Commerce Clause and violated other parts of the Constitution. A three-judge District Court upheld the constitutionality of Title II, §§ 201(a), (b)(1) and (c)(1), the provisions attacked, and, on appellees' counterclaim, permanently enjoined appellant from refusing to accommodate Negro guests for racial reasons.
1. Title II of the Civil Rights Act of 1964 is a valid exercise of Congress' power under the Commerce Clause as applied to a place of public accommodation serving interstate travelers. Civil Right Cases, 109 U. S. 3, distinguished. Pp. 379 U. S. 249-262.
(a) The interstate movement of persons is "commerce" which concerns more than one State. Pp. 379 U. S. 255-256.
(b) The protection of interstate commerce is within the regulatory power of Congress under the Commerce Clause whether or not the transportation of persons between States is "commercial." P. 379 U. S. 256.
(c) Congress' action in removing the disruptive effect which it found racial discrimination has on interstate travel is not invalidated because Congress was also legislating against what it considered to be moral wrongs. P. 379 U. S. 257.
(d) Congress had power to enact appropriate legislation with regard to a place of public accommodation such as appellant's motel even if it is assumed to be of a purely "local" character, as Congress' power over interstate commerce extends to the regulation of local incidents thereof which might have a substantial and harmful effect upon that commerce. P. 379 U. S. 258.
(2) The prohibition in Title II of racial discrimination in public accommodations affecting commerce does not violate the Fifth Amendment as being a deprivation of property or liberty without due process of law. Pp. 379 U. S. 258-261.
(3) Such prohibition does not violate he Thirteenth Amendment as being "involuntary servitude." P. 379 U. S. 261.
231 F.Supp. 393, affirmed.