Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241 (1964) was a U.S. Supreme Court Case confirming that Congress did not go beyond their scope of power to regulate commerce, under Article I, Section 8, Clause 3 of the Constitution of the United States. Although one of the main reasons behind the ratification of the 14th Amendment was to rid United States of public discrimination. Many states chose to ignore this portion of the Constitution, and continued with the unfair treatment of African Americans. There were many states that even decided to pass “Jim Crow Laws” which allowed them to continue to segregate facilities which were open to the general public.
In an unanimous 9-0 opinion, the Supreme Court held that within the scope of the Commerce Clause, Congress did have the authority to regulate the motel’s operations.
The decision handed down in Heart of Atlanta Motel Inc. v. United States, was not only significant in showing the power of Congress to pass legislation under the Commerce Clause, but also in overturning the Jim Crow system.
Heart of Atlanta Motel, Inc. v. United States is especially prevalent when considering its direct impact on upholding the Civil Rights Act of 1964 which directly attempts to provide access to public facilities and public accommodations, such as restaurants and hotels. The employment provisions of the law are often referred to as “Title VII,” based on their location in the U.S. Code. The act was passed on July 2, 1964 and the Heart of Atlanta case was argued in Supreme Court on October 5, 1964, and it was decided by December 15, 1964. The historical relevance is very important in denoting why this act was supported vs. previous Civil Rights Acts passed by Congress that failed to be enforced or were deemed unconstitutional.
The case of Heart of Atlanta Motel, Inc. v. United States argued against Congress’s ability to regulate private businesses under the Commerce Clause in Article I of the Constitution and Section 5 of the 14th Amendment in the Bill of Rights. To greater understand the case’s significance within American history, it is necessary to understand what led to the rapid acceptance and support for the Civil Rights of of 1964 when the Civil Rights Acts of 1866, 1871, 1875 were deemed unconstitutional, and the acts of 1957, and 1960 were under enforced.
The Civil Rights Act of 1875 is the most important legislation to note, as over seventy-five years would pass before the government put forth more legislation associated with Civil Rights. The Civil Rights Act of 1875 would guarantee African Americans equal treatment in public accommodations, public transportation, and to prohibit exclusion from jury service. The goal of the Act was to strengthen the cause of post Civil War era laws and efforts to reform the Southern United States. The Reconstruction period, as it’s known, saw the most African Americans in political seats in any time period in Southern U.S. history. With the fall of the recent Confederacy many efforts toward equality were made by the Republicans in power.
The Civil Rights Act of 1875 came under scrutiny during Civil Rights Cases of 1883, the collection of five cases compiled by the Supreme Court, when Congress’s authority to govern the actions of private citizens under the CRA 1875 was challenged to be unconstitutional. The Civil Rights Acts all sought to end discrimination in public spaces just like the act of 1964, but Congress tried to use its powers under the 13th and 14th amendment to argue that by equal protection under the law that citizens had a right to not be discriminated even by private business owners. The Supreme Court however interpreted that the goal of the equal protection clause was to stop governmental entities such as states from discriminating against individual citizens. Further the Supreme Court would rule that Congress could not impact the rights of private citizens on operating their own enterprises.
Coming full circle the case of Heart of Atlanta Motel fits the same mold as the Civil Rights Cases of 1883, and if the U.S. used the 13th and 14th amendments to defend the Civil Rights Act of 1964 then the act would likely of been defeated with the precedent set from 1883. Instead the commerce clause was used, resting heavily on precedent set by the Wickard vs. Filburn case of 1942. The expedient nature of Heart of Atlanta Motel, Inc. vs. United States makes it evident that this case was hand picked and used as a means by which to defend a Civil Rights bill, something that hadn’t successfully been done in the past. It is however important to note that approaching the case through the commerce clause hinged on demoralizing the issue of racism. Justice Goldberg in his concurring opinion would note that being racially profiled is not a simple matter of dollars and cents, but one associated with a great level of humiliation. To not acknowledge these moral wrongdoings in dealing with the case serves a great disservice to the principle argument of the U.S. in Goldberg’s opinion. Subsequent cases hinging on moral implication would thus be forced to follow the same model, void of a moral reasoning and only focusing on economic activity.
On July 2,1964, only a few hours after the passing of the Civil Rights Act of 1964, Moreton Rolleston, owner of the Heart of Atlanta Motel filed suit in the U.S. District Court for the Northern District of Georgia, asking that the Civil Rights Act of 1964 be found unconstitutional, because Congress would be going beyond its powers of commerce if they prohibited racial discrimination in private spaces.
July 22, 1964 the U.S. District Court for the Northern District of Georgia upheld the constitutionality of Title II under the Civil Rights Act of 1964 and issued a permanent injunction requiring the motel to cease discriminating against black customers.
Mr. Rolleston appealed the district court’s decision to the Supreme Court where it was argued on October 5th 1964.
On December 14, 1964, the Supreme Court issued its decision for the case, upholding the lower court’s decision.
- Are the powers giving to Congress under the Commerce Clause enough to allow them to force private businesses to abide by Title II of the Civil Rights Act?
- Did Congress violate Section I of the 14th Amendment by forcing the owner of Heart of Atlanta Motel to not choose his customers without out the presence of discrimination?
- Did Congress violate the Due Process Clause of the 5th Amendment when they tried to deny the owner to control his property as he say fit?
- Would forcing the owner of the hotel to open his doors to African Americans, be considered an act of involuntary servitude under the 13th Amendment?
Arguments by Petitioner
Moreton Rolleston, the owner of Heart of Atlanta, filed suit arguing that the Title II of the Civil Rights Act of 1964, which banned racial discrimination in public places, went over and above its limit and that the requirements of the Act exceeded the authority granted to Congress. Rolleston argued that Congress exceeded its Commerce Clause powers to regulate interstate commerce. The Petitioner also argued that his Fifth Amendment rights were violated because he could not choose and pick the customers he wished to operate too. The last thing that the petitioner argued was that his Thirteenth Amendment rights were being violated. He stated that Congress was forcing him to participate in involuntary servitude by forcing him to rent out rooms to blacks. Rolleston previously lost his suit in the U.S. District Court for the Northern District of Georgia.
Arguments by Respondent
The attorneys for United States of America responded by stating that by not serving Blacks, and the restrictions placed upon them, through public accommodations directly affected interstate travel. They said that the case fell into the category of Commerce power which could be controlled by Congress. The respondent (U.S.) also stated that the Fifth Amendment does not forbid regulation of interstate commerce and that the Thirteenth Amendment does not apply to this case since the amendment applied primarily to slavery and the removal of disabilities associated with it.
In a 9-0 vote, the Justices agreed that Congress has the right to prohibit discrimination in the Heart of Atlanta Hotel under the Commerce Clause, but Justice Douglas, Black, Goldberg have a concurrence about whether the Commerce Clause was the most accurate grounds to enforce this. Everyone agreed that the Civil Rights Act doesn’t violate the 5th and 13th Amendment.
Majority Opinion (Clark)
Justice Clark wrote the majority opinion which The Supreme Court held that “the action of the Congress in 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” (Heart of Atlanta Motel v. U.S., 1964). The huge deciding factor in the case was the location of the institution. The Heart of the Atlanta Hotel’s location is in very close proximity to the interstates of 75 and 85 and two major Georgia highways. According to reports, 75% of the Heart of Atlanta’s clientele were out-of-state residents. That being the case, the Court found that the business affected interstate commerce in terms of the black out-of-state visitors.
The discrimination of blacks in the motel is problematic in the Heart of Atlanta Motel due to its effect on commerce. If the statistics are true about the amount of out-of-state residents that the motel provides rooms for, then a good portion of blacks must travel through from out-of-state. If the word gets around that the Heart of Atlanta Motel doesn’t accept blacks, less black people will travel through the area due to a lack of housing. They would have to find other hotels in different areas, which definitely affects interstate commerce.
The supreme court also ruled that because denying business to african americans, it would have a substantial impact on interstate commerce which could not be regulated by the state’s only by congress. Therefore it was their reasoning that congress had not violated section 5 of the fourteenth amendment in implementing and enforcing this law.
The court’s holdings on Rolleston claim that the law violated his 5th and 13th amendments were that congress had neither force Rolleston into involuntary servitude ,and was so insubstantial that the court did not need to discuss it any more, or deprived him of property or liberty because he was still being financially compensated for his rooms.
Concurring Opinion (Black)
Justice Black wrote a concurring opinion, which was joined by Justices Goldberg and Douglas. Black joins in the opinion of the majority that the Court has the constitutional power to enforce authority over businesses that might affect interstate commerce among states under the Commerce Clause. He assures that the argument presented by the motel’s proprietors regarding the violation of Due Process Clause of the 5th Amendment is not applicable to this case. However, Black states that the majority opinion didn’t discuss the power of Congress in congruence with the Commerce and Necessary and Proper clauses to pass a law forbidding such racial discrimination. He includes that this motel had a substantial buying power of goods, and if discrimination was allowed, then it could disrupt the flow of interstate commerce on wide scale. He claims that because the Civil Rights Act of 1964 is valid under the Commerce Clause and the Necessary and Proper Clause, there is no need to consider whether the Act is constitutionally supportable under section 5 of the Fourteenth Amendment.
Concurring Opinion (Goldberg)
Justice Goldberg wrote a concurring opinion, which was joined by Justices Black and Douglas.Goldberg joins the opinion that Congress has the right to enact Civil Rights Act under the Commerce Clause. However, Goldberg believes that the Act’s main purpose is to prohibit racial discrimination and the promotion of equal rights to public accommodation. He makes a strong case under his opinion to illustrate the humiliation of those being affected by discrimination, and that under his nature this decision would have had solved this problem using the Civil Rights Act.This is a right granted by the Fourteenth Amendment, so he feels like the decision should have been based on this besides the Commerce Clause. But, even though he believes that Sections I and IV should be noted to implement the majority decision, it is fashionably utilize the Commerce Clause to implement and administer these rights to enact the Civil Rights Act of 1964.
Concurring Opinion (Douglas)
Justice Goldberg wrote a concurring opinion, which was joined by Justices Black and Goldberg. Douglas joins the majority in the opinion that the Commerce clause does grant Congress the power to enforce authority over businesses that affect interstate commerce. That being the case, Douglas argues that the argument should have rested on the Fourteenth Amendment, which in his opinion would have been a more settling effect. He points out that the decision should have been based under the 14th Amendment, and effectively end any future strategies created to neglect public accommodation due to race, color, or even creed. Douglas claims that the right to be free of discriminatory treatment (based on race) in places of public accommodation — whether intrastate or interstate– is a right guaranteed against state action by the Fourteenth Amendment. Overall, he supports that under the 14th Amendment the decision would apply to all customers without exceptions, and to all enumerated places of public accommodations.
Full Text of Opinions
- Majority Opinion (Clark)
- Concurring Opinion (Douglas)
- Concurring Opinion (Black)
- Concurring Opinion (Goldberg)
The “State Action Doctrine” was upheld in this case, meaning the Supreme Court upheld the old precedent under the 14th amendment, which only banned discrimination by state actors (i.e. the state taking “action”), not by private actors. Although the Supreme Court decided to uphold the “State Action Doctrine”, that decision played no part in the passing of the Civil Rights Act of 1964, mainly due to the Court deciding to pass this Act under the Commerce Clause. This meant that not only were they able to uphold the old precedent, but they were also able to find another way to ban discrimination in privately owned public accommodations. The decision of the Heart of Atlanta Motel case was significant in the dismantling of the Jim Crow system because it upheld the Civil Rights Act of 1964, which allowed Congress to regulate private businesses if it affected commerce. The Heart of Atlanta Motel case also upheld the old precedent of the Civil Rights Cases (1883), which established the State Action Doctrine– meaning that Congress could not regulate private actions.
The Court’s decision also impacted future cases. Even though upholding the Civil Rights Act of 1964 was significant in dismantling the Jim Crow laws (i.e. privately owned accommodations could no longer discriminate if it affected commerce), it also allowed other important civil cases to be overturned. In U.S. v Morrison (2000), the Court overturned the Violence Against Women Act because they ruled that it was unconstitutional under section 5 under the Fourteenth Amendment, where is says “no state shall…” (Anderson, 2001). However, some arguments can be made that the Court could have ruled in favor of the VAWA because of section 5 that says “The Congress shall have power to enforce, by appropriate legislation, the provisions of this article,” meaning that the Congress could enforce legal remedies for private businesses if it violates Section I. An argument is made that it violates Section 1 of the 14th Amendment because it deters women from turning to authority when they are raped, causing them to have no equal protection under the law (Anderson, 2011). Because women felt like they could not turn to the law for help, they were not given equal protection. In other words, they are less likely to turn to the government for help whereas males did not have this issue. Balkin argues that if the Court decided to overturn the old precedence of the Civil Rights Cases, then the VAWA could have been passed. But since the State Action Doctrine was upheld in The Heart of Atlanta Motel v United States, the Court could not uphold the VAWA. It ended up being overturned because it did not uphold the substantial effect doctrine and it also went against the precedent set in the State Action Doctrine.
Scholarly Commentary and Debate
- Article I, Section 8, Clause 3 – Commerce Clause
- 5th Amendment – Due Process Clause
- 13th Amendment
- 14th Amendment Section 1 – Privileges and Immunities Clause
Government Law or Action Under Review
Important Subsequent Cases
Read these sites in order to best review and understand the Heart of Atlanta Motel case
Anderson, Michelle J. “Women Do Not Report the Violence They Suffer: Violence against Women and the State Action Doctrine.” Villanova Law Review 46.5 (2001): 907-950.
Balkin, Jack M. “Reconstruction Power, The.” NYUL Rev. 85 (2010): 1801.
Cortner, Richard. 1997. “ Civil Rights and Public Accommodations: The Heart of Atlanta and the McClung Cases” (Lawrence, KS : University Press of Kansas, 2001). (Accessed May 1. 2016).
“Heart of Atlanta Motel, Inc. v. United States.” LII / Legal Information Institute. Accessed April 13, 2016. https://www.law.cornell.edu/supremecourt/text/379/241#writing-USSC_CR_0379_0241_ZO.
- This source gives the entire written majority opinion along with the concurring opinions of Justice Black, Douglas, and Goldberg.
“Heart of Atlanta Motel, Inc. v. United States.” Oyez.. Accessed April 13, 2016. Retrieved October 4, 2015, from https://www.oyez.org/cases/1964/515
- This source is a simplified case brief of the case, which helps to know the bare essential facts and decisions of the case.
“Heart of Atlanta Motel, Inc. v. United States 379 U.S. 241 (1964).” Justia Law. Retreived from October 5, 2015. Accessed April 13, 2016. https://supreme.justia.com/cases/federal/us/379/241/case.html.
- This source also provides the entire written majority and concurring opinions, but adds more contextual history for the case.
“Heart of Atlanta Motel, Inc. v. United States, 231 F. Supp. 393 (N.D. Ga. 1964).” Justia Law. Retrieved on October 5, 2015. Accessed April 13, 2016. http://law.justia.com/cases/federal/district-courts/FSupp/231/393/1444943/
- This source provides the case of Heart of Atlanta Motel in the Atlanta District Court, which is useful to see what his arguments were.
Kloster, A. (2014, April 14) “Heart of Atlanta Motel: Public Accommodation Law at 50.” The Heritage Foundation. Retrieved December 2, 2015. Accessed April 13, 2016. http://www.heritage.org/research/reports/2014/04/heart-of-atlanta-motel-public-accommodation-law-at-50.
- Kloster analyzes the Civil Rights Act and Commerce Clause and discusses how the Heart of Atlanta Motel case gave Congress authority to enforce the Civil Rights
“Long Road to Justice – Public Accommodations.” The Leadership Conference on Civil and Human Rights. Retrieved Dec 2, 2015. Accessed April 13, 2016. http://www.civilrights.org/publications/reports/long-road/accommodations.html?referrer=https://www.google.com/
- This source gives an anecdote about a couple and their kids who, while taking a trip, are reminded of the racial discrimination that was allowed in hotels and restaurants. The source then gives details about the Heart of Atlanta case, since it was the first case that showed that Congress has the authority to enforce anti-discrimination in private businesses.
McClain, Linda C. “Involuntary Servitude, Public Accommodations Laws, and the Legacy of Heart of Atlanta Motel, Inc. v. United States.” 2011. Accessed April 16, 2016. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2188939.
- This source is an abstract from a study about how the Commerce Clause used in the context of Heart of Atlanta Motel was the foundation for other public accommodation laws and anti-discriminatory laws.
Stern, R. “The Commerce Clause Revisited – The Federalization of Intrastate Crime.” 15 Arizona Law Review 1973. Accessed April 16, 2016. http://heinonline.org/HOL/LandingPage?handle=hein.journals/arz15.
- This source is an abstract explaining how through the Commerce Clause, Congress can control pretty much any business transaction between states.
“Key Supreme Court Cases: Heart of Atlanta Motel v. U.S. (ABA Division for Public Education).” Key Supreme Court Cases: Heart of Atlanta Motel v. U.S. (ABA Division for Public Education). Accessed April 16, 2016. http://www.americanbar.org/groups/public_education/initiatives_awards/students_in_action/atlanta.html
- This source is a case brief of the Heart of Atlanta Motel v. U.S. case, but also adds its significant impact on future cases.
Coenem, D. “Heart of Atlanta Motel v. United States (1964).” New Georgia Encyclopedia. May 17, 2013. Accessed April 16, 2016. http://www.georgiaencyclopedia.org/articles/government-politics/heart-atlanta-motel-v-united-states-1964
- This source gives a historical account of the case and its companion case, Katzenbach v. McClung. It also gives context to the environment of both cases and its impact on future cases.
Chen, J. “Come Back to the Nickel and Five: Tracing the Warren Court’s Pursuit of Equal Justice Under Law.” August 16, 2005. Accessed April 16, 2016. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=773025.
- This source gives an evaluation of the Court’s history of enforcing due process and the Commerce Clause.
Academic Books, Articles and Law Reviews
Spring 2016: Gabriela Batista-Vargas, Sana Cheema, Vaughn Fray, Zenobia Haynes, & Francisca Stevens
Fall 2015: Gregory Joseph, Joseph Mears, Erick S. Taylor Jr., Brittany Walton, Moe Hanson