Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241; 85 S. Ct. 348; 13 L. Ed. 2d 258 (1964)

Facts—The owner of a large motel in Atlanta, Georgia, which restricted its clientele to white persons, brought suit for a declaratory judgment and for an injunction to restrain enforcement of Title II of the Civil Rights Act of 1964, which outlawed distinguishing on the basis of race, color, religion, or national origin in making available public accommodations.

Question—Does Congress have the power to outlaw racial discrimination in public accommodations under its power to regulate interstate commerce?

Decision—Yes.

Reasons—J. Clark (9–0). The power of Congress over interstate commerce includes the power to regulate local incidents and activities in both the states of origin and destination of the commerce that might have a substantial and harmful effect on that commerce. The Court concluded that “the action of the Congress in the adoption of the 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.” In a concurring opinion, J. Douglas argued that the Court should place greater reliance on congressional powers to enforce civil rights through Section 5 of the Fourteenth Amendment rather than focusing on the commerce clause.

Note—This decision evaded the limitations imposed in the Civil Rights Cases, 109 U.S. 3 (1883) by focusing on federal powers under the commerce clause rather than on the Fourteenth Amendment, which reached only state actions. The Court applied the doctrine from Heart of Atlanta Motel in a companion case, Katzenbach v. McClung, 379 U.S. 294 (1964), involving a restaurant that purchased much of its food through interstate commerce.

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