Heart of Atlanta Motel was a 216-room motel in Atlanta, located near interstate highways and heavily soliciting interstate business through national advertising and in-state billboards. About 75% of its guests were from out of state, and the motel served transient travelers. Before and after passage of Title II of the Civil Rights Act of 1964, the motel refused to rent rooms to Black patrons and stated it intended to continue doing so. The motel sued for declaratory and injunctive relief, arguing Title II was unconstitutional, and the United States counterclaimed to enforce the Act.
Did Congress, under the Commerce Clause, have authority to apply Title II of the Civil Rights Act of 1964 to a privately owned motel serving interstate travelers and forbidding racial discrimination in lodging?
Congress may regulate local business conduct under the Commerce Clause when that conduct exerts a substantial and harmful effect on interstate commerce. Racial discrimination by places of public accommodation serving interstate travelers may be prohibited when it burdens interstate travel and commerce.
Yes. Title II of the Civil Rights Act of 1964, as applied to Heart of Atlanta Motel, was a valid exercise of Congress's power under the Commerce Clause. The motel's Fifth and Thirteenth Amendment objections were rejected.
The Court emphasized the motel's clear connection to interstate commerce: it solicited national business, was accessible from interstate highways, and served predominantly out-of-state guests. Congress had compiled extensive evidence showing that racial discrimination in hotels and motels impeded interstate travel, burdened commerce, and created serious obstacles for Black travelers. Because Title II was narrowly directed at establishments affecting commerce, it differed from the statute invalidated in the Civil Rights Cases, 109 U.S. 3 (1883). The Court also held that requiring the motel to comply with federal regulation was not an unconstitutional taking or deprivation of liberty, nor did it amount to involuntary servitude.
Heart of Atlanta Motel is a foundational decision upholding the Civil Rights Act of 1964 and confirming that Congress may use the Commerce Clause to combat racial discrimination in public accommodations. It marked a major shift from the limits associated with the Civil Rights Cases, 109 U.S. 3 (1883), by tying the statute to concrete effects on interstate commerce. It is closely paired with Katzenbach v. McClung, 379 U.S. 294 (1964), which upheld Title II as applied to a restaurant, and it rests on broad modern Commerce Clause principles reflected in Wickard v. Filburn, 317 U.S. 111 (1942).
109 U.S. 3 (1883) |
Abstain |
Katzenbach v. McClung, 379 U.S. 294 (1964) |
Abstain |
Wickard v. Filburn, 317 U.S. 111 (1942) |
Abstain |
109 U.S. 3 (1883) |
Abstain |
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