Heart of Atlanta Motel v. United States, 1964
Racial Discrimination in Privately Owned Facilities
★★★ Background of the Case ★★★
The ground-breaking Brown decision of 1954 banned racial discrimination in public schools and was gradually extended to other public facilities. The ruling did not apply to privately owned places such as hotels and restaurants. As a result, many of these places continued to refuse to accommodate African Americans. Professional baseball teams, for example, which had become racially integrated in 1947, could do nothing when their African American players were not allowed to register at the same hotels as the white players.
Civil liberties lawyers tried to find some constitutional way to make these discriminatory practices illegal. The lawyers first had to prove that the federal courts had jurisdiction over these places, and second that they violated the Civil Rights Act of 1964. This act forbade racial discrimination by hotels, restaurants, theaters, and other public accommodations.
The Heart of Atlanta Motel was located in downtown Atlanta, but had ready access to two interstate highways. The motel solicited guests from outside Georgia by advertising in various national media. It also accepted reservations for conventions from organizations outside of Georgia. About 75 percent of its business came from outside the state.
Before the passage of the Civil Rights Act, the motel refused to rent its rooms to African Americans and stated that it planned to continue to do so. In order to do so legally, the motel sued the United States government, which had the responsibility of enforcing the Civil Rights Act. Through the appeal process, the case reached the United States Supreme Court.
★★★Constitutional Issue ★★★
The motel based its appeal on three claims. First, it claimed that the Civil Rights Act was unconstitutional because it exceeded Congress’s power to regulate commerce under the commerce clause of the Constitution. Second, the motel asserted that the Civil Rights Act violated the Fifth Amendment because, in being deprived of the right to choose its customers and operate its business as it wished, its liberty and property were being taken from it without due process of law and its property was taken without just compensation. Third, it claimed that requiring the motel to rent rooms to African Americans against its will subjected it to involuntary servitude in violation of the Thirteenth Amendment.
The Court had to decide whether the Civil Rights Act deprived the motel owners of their constitutional rights.
★★★ The Supreme Court’s Decision ★★★
The Court ruled against the motel in a decision written by Justice Tom C. Clark. The Court chose to deal only with the question of whether the Civil Rights Act was constitutional because it was based on the power of Congress to regulate interstate commerce. Justice Clark cited earlier cases which dealt with the meaning of interstate commerce and Congress’s power to regulate it. As to the constitutionality of the Civil Rights Act of 1964, the Court held that the commerce clause of the Constitution permitted Congress to ban discrimination in places like the motel. Clark cited the Gibbons v. Ogden case and other cases that defined the meaning of “interstate commerce” in such a way as to include the business of the motel. It denied that the business of the motel was purely local since a good portion of its business was with people from other states.
Clark closed: “We . . . conclude that the action of the Congress in the adoption of the [Civil Rights] Act as applied here to a motel which concededly serves interstate travelers is within the power granted it by the Commerce Clause of the Constitution, as interpreted by this Court for 140 years. It may be argued that Congress could have pursued other methods to eliminate the obstructions it found in interstate commerce caused by racial discrimination. But this is a matter of policy that rests entirely with the Congress not with the courts. How obstructions in commerce may be removed — what means are to be employed — is within the sound and exclusive discretion of the Congress. It is subject only to one caveat — that the means chosen by it must be reasonably adapted to the end permitted by the Constitution. We cannot say that its choice here was not so adapted. The Constitution requires no more.”
On the same day, the Court also ruled on a closely related case, Katzenbach v. McClung. The decision in this case, also written by Justice Clark, dealt with a Birmingham restaurant that mainly served a local clientele. It served African Americans but only at a takeout counter. About half the food the restaurant served came from out of state. The Court’s opinion indicated that this fact was not crucial in its ruling. It took the stand that discrimination in a public accommodation such as a restaurant severely hindered interstate travel by African Americans.
In a concurring opinion, Justices William O. Douglas and Arthur J. Goldberg argued that the commerce clause was not the only constitutional support for the Court’s view of interstate commerce, but also that the Fourteenth Amendment empowered Congress to impose the regulations provided in the Civil Rights Act of 1964.
★★★ Questions ★★★
DIRECTIONS: Answer the following questions on a separate sheet of paper.
1. What do you think the Court’s decision in the Atlanta case required the motel to do?
2. Why do you think the Court chose to deal only with the commerce clause rather than the other two questions the motel had raised as well?
3. What did the Court’s decisions in both the Atlanta and Birmingham cases have in common?
4. Justice Clark had a reputation for being a very conservative member of the Supreme Court. Do you think his rulings in the two cases described supported or detracted from this reputation? 5. Do you think the Court was correct in broadening its interpretation of the commerce clause? Explain.
