Heart of Atlanta Motel, Inc. v. United States


Congress passed the Civil Rights of 1964, a portion of which banned racial discrimination in public places with public accommodations, citing the interstate commerce clause as their authority.  Plaintiff rented a large motel in Atlanta and refused to offer rooms to African Americans.  The owner sued, stating that the act exceeded Congress’s ability to regulate interstate commerce.  The US government argued that the travel of African Americans between states was impacted by their inability to stay in public accommodations.  The trial court sided with the US government and ordered the Plaintiff to serve African Americans.


Whether Congress may force a private business owner to serve African Americans based on their constitutional ability to regulate interstate commerce.


Yes, affirmed.  Roughly 75 percent of Plaintiff’s clientele come from out of state and was clearly located near two major federal, interstate highways.  The business’s location and public nature clearly accommodate and impact interstate commerce, according to the court.  The court wrote that “…the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the States of origin and destination, which might have a substantial and harmful effect upon that commerce. One need only examine the evidence which we have discussed above to see that Congress may—as it has—prohibit racial discrimination by motels serving travelers, however ‘local’ their operations may appear.”  The American population is becoming more and more mobile and African American population’s inability to find an accommodation for travel represents a substantial and harmful effect upon commerce.

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