Heart of Atlanta Motel, Inc. v. United States Summary | quimbee.com


– [Narrator] In 1964, the
Heart of Atlanta Motel found itself at the heart of a landmark civil rights dispute. In Heart of Atlanta Motel
versus United States, the United States
Supreme Court established the foundation for the use of Congress’s Commerce Clause powers
to protect civil rights. Congress enacted the
Civil Rights Act of 1964 to prohibit discrimination
on the basis of race in any place of public accommodation. A place of public
accommodation was defined to include among other
things motels and restaurants if their operations substantially affect interstate commerce. The Heart of Atlanta Motel was located in its namesake city. The motel advertised in national media, it was situated conveniently
next to interstate highways and approximately 75% of its business came from out of state guests. The motel also practices a policy of refusing to rent rooms
to African Americans. The motel brought a lawsuit against the United States government seeking a declaratory
judgment that Congress had exceeded its constitutional authority by enacting the Civil Rights Act. The motel also alleged
that the act violated its due process rights by depriving it of the right to select its customers and operate its business as it wished. A three judge district court panel upheld the Civil Rights
Act as constitutional under the Commerce Clause
and prohibited the motel from discriminating
against African Americans. On direct appeal, the issue
before the Supreme Court was whether Congress can
prohibit racial discrimination by places of public accommodation using its Commerce Clause authority. In an opinion by Justice Clark, the court held that
Congress can enact laws that prevent racially
discriminatory policies in hotels serving interstate travelers because these policies
substantially affect interstate commerce. The court observed the Congress’s power to regulate interstate commerce includes the power to regulate
local incidents of commerce that have a substantial relation to the interstate flow of goods. As a result the court
reasoned that Congress has the power to remove local obstructions and restraints to interstate commerce. The court also reviewed
the congressional record for the Civil Rights Act. The record established
that racial discrimination has a disruptive effect
on interstate travel by substantially discouraging travel by African Americans. With no place to stay while traveling, African Americans were
not able to move freely from state to state and this created a drag on interstate commerce. Therefore, the court held
that the Civil Rights Act, as applied to places
of public accommodation that serve interstate
travelers, was a valid exercise of Congress’s Commerce Clause authority. The court affirmed the
district court’s order enjoining the motel from discriminating on the basis of race. In a concurring opinion,
Justice Black agreed that Congress had the power to regulate the motel’s activities
under the Commerce Clause. Noting that the motel
was a large establishment that advertised extensively
on interstate highways, Black concluded that the motel’s racial discrimination policies had a great impact on interstate commerce. Additionally, Black rejected
the motel’s argument that the act violated
its due process rights. For one thing, regulating
the use of private property isn’t a constitutional taking
under the Fifth Amendment. Additionally, the Fourteenth Amendment, which was adopted to
prohibit discrimination, can’t be used to strip
Congress of its power to protect African Americans
from further discrimination. Justice Douglas, in
another concurring opinion, argued that the court
shouldn’t have rested its decision on the Commerce Clause. By relying solely on Congress’s authority to regulate interstate commerce the majority implied that an
impact on interstate commerce is a prerequisite for protection
against discrimination. But for Douglas this
prerequisite was unnecessary. Instead he argued that a stronger and broader basis for Congress’s authority could be found under Section 5 of the Fourteenth Amendment. Section 5 grants Congress
the power to enforce, by appropriate legislation, the right of all persons to equal protection of the law. Finally, Justice
Goldberg, also concurring, reasoned that the majority opinion should rest on both the
Fourteenth Amendment and the Commerce Clause, rather than on one or the other. For Goldberg, Congress had clear authority under both provisions to
enact the Civil Rights Act. Heart of Atlanta Motel
versus United States was a landmark Civil Rights
decision that allowed Congress to use its Commerce Clause powers to combat racial discrimination.

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