Heart of Atlanta Motel v. U.S.

Private Discrimination

Facts of the Case

Title II of The Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce. The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans and was charged with violating The Civil Rights Act of 1964. The motel owner in Atlanta served mostly interstate travelers. He claimed that Congress had exceeded its authority under the Commerce Clause by regulating a local private business. He also claimed that the law should be declared invalid under the due Process Clause of the Fifth Amendment and Thirteenth Amendment.

Whats is the Constitutional Question?

Did Congress in passing Title ll of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to chose their own customers?

Under the constitution can congress pass a law preventing private businesses from discriminating against people?

The owner of the Heart of Atlanta Motel,Inc

The owner of the Heart of Atlanta Motel, claimed that with them charging him for violating the Civil Rights Act of 1964 that they where violating his 5th and 13th Amendment. The Fifth Amendment states that no person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a grand jury, except in cases arising in the land or naval forces, or in the militia, when in actual service in time of war or public danger; nor shall any person be subject for the same offense to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation. The Thirteenth Amendment abolished slavery and involuntary servitude, except as punishment for a crime. These amendments however, had nothing to do with what he was accused of violating.
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The Conclusion

The court held that the Commerce Clause allowed Congress to regulate local incidents of commerce, and that the Civil Right Act of 1964 passed constitutional muster. The Court noted that the applicability of Title ll was "carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people. . ."The court therefore concluded that places of public accommodation had no "right" to select guests as they saw fit, free from government regulation. The Court upheld the law.

The Impact of the Decision

With the law upheld, a very powerful legal tool was available to enforce equal treatment. Over the years, there have been fewer and fewer instances of overt [direct] racial discrimination in public accommodations.

More Information

  • The Civil Rights Act of 1964 is a landmark piece of civil rights legislation in the United States that outlawed discrimination based on race, color, religion, sex, or national origin.
  • Title ll of the Civil Rights Act of 1964 prohibits discrimination because of race, color, religion or national origin in certain places of public accommodation, such as hotels, restaurants, and places of entertainment.
  • The Commerce Clause refers to Article 1, Section 8, Clause 3 of the U.S Constitution, which gives Congress the power"to regulate commerce with foreign nations, and among the several states,and with the Indian tribes."