Heart of Atlanta Motel, Inc. v. United States
379 U.S. 241 (1964)
Constitutional Topic Areas:
Article I §VIII Clause III “Commerce Clause,” Federalism, Appellate Jurisdiction, 5th Amendment ‘Due Process Clause’
Case Facts:
With the passing of the Civil Rights Act of 1964, Congress sought to prohibit discrimination on the basis of sex, race, religion, color, and/or national origin, in any public place which had a substantial affect on interstate commerce, such as restaurants and motels/hotels with more than five rooms total. The Heart of Atlanta motel was located within the Atlanta metropolitan area and advertised heavily throughout the state with billboards, and nationally by other means. The Heart of Atlanta motel did most of its business with people traveling from other states. The motel also had a policy of denying service to African-Americans, which was in direct violation of the Civil Rights Act of 1964. The Heart of Atlanta motel sued the federal government, specifically challenging the constitutionality of Title II within the CRA of 1964.
Questions:
1. Does Congress have the authority under its Commerce Clause powers to enforce Title II of the CRA to prohibit racial discrimination in places of public accommodation?
Holding:
1. Yes
Legal Reasoning: Justice T.C. Clark (9-0)
1. Congress has the authority under its commerce clause powers to regulate anything that may have a substantial affect on interstate commerce. Additionally, Congress may regulate local incidents of commerce which have a large impact upon the interstate flow of goods
2. The Heart of Atlanta motel does most of its business from interstate travelers. The court referenced the 1964 Civil Rights Act Congressional Record which stated racial discrimination discourages African-Americans, dramatically disrupting interstate commerce
3. Under the precedent established in Gibbons v. Ogden, Congress can regulate intrastate travel
4. The Civil Rights Act of 1964, when applied to public places which serve interstate travelers, is a valid use of Congress’ commerce clause powers
Significance:
Heart continues the Supreme Court’s expansionism of Congress’ Commerce Clause power. Additionally, this case sets a precedent of the Commerce Clause’s application to civil rights issues. This case upholds Title II of the 1964 CRA prohibiting private discrimination by businesses engaging in the sphere of interstate commerce. Moreover, Heart’s implicitly strong unanimous ruling establishes the case’s precedent and unlikeliness to be overturned in the future
Reflection:
Heart set a strong precedent which is the basis of modern anti-discrimination law. This precedent still stands in the modern era and plays a foundational role in anti-discrimination litigation. With the Supreme Court’s continued expansionism of Congress’ Commerce Clause powers, we can expect a further continuation of this expansionism into the short term future. Overall, Heart broadened the power of the federal government
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