Heart of Atlanta Motel v United States
S. Ct. 1964
Author: Sam Biers

Facts:   The PL, an owner of a Motel in Georgia, which is easily accessible to the two main interstate highways.  The motel solicits its patronage from within Georgia as well as nationally, where 75% of it registered guests originate.  Prior to the passage of the Civil Rights Act, the motel had a policy of refusing service to African Americans, and intended to continue that practice. 

Issue:   Whether the refusal of motel patrons who are African-American is in violation of Title II? 

Holding: Yes

Procedure:  Pl filed for declaratory relief attacking Title II of the Civil Rights Act of 1964. Defendants counterclaimed for enforcement and asked for three-judge district court The three-judge court, convened in the United States District Court for the Northern District of Georgia and sustained the validity of the Act and issued a permanent injunction on the counterclaim, and plaintiff appealed. The Supreme Court held that the public accommodations provisions of the Civil Rights Act of 1954 are valid under the Commerce Clause. Affirmed.

Rule: If an activity sought to be regulated is commerce which concerns more States than one and has a real and substantial relation to the national interest, it falls under the Commerce Clause.  Commercial intercourse(Gibbon v Ogden) shall include the movement of persons through more than one State.

Ct Rationale: Discrimination or segregation by hotels and motels impedes interstate travel.  Public accommodations provisions of Civil Rights Act, as applied to a restaurant serving food, a substantial portion of which had moved in interstate commerce, was valid exercise of power of Congress to regulate interstate commerce.  A motel which concedely serves interstate travelers is within the power granted by the Commerce Clause.

PL A: The operation of the motel is of a purely local character and does not affect the nation.

Def A: Racial discrimination disrupts commercial intercourse and has a real and substantial relation to the national interest.

All persons shall be entitled to the full and equal enjoyment of the g& s, facilities, and accommodations of any place of public accommodation w/o discrim, or segr. on the ground of race, color, religion, or national origin.  4 classes of bus., (any inn, hotel, motel, or other establishment which provides lodging to transient guests with more than five rooms for rent or hire or actually occupied by the proprietor), its operation affects commerce, discrim/segr is the deprivation of personal dignity that accompanies denials of equal access to pub establ.

Civil Rights Act provides statutory proceeding for determination of rights and duties arising thereunder, courts should ordinarily refrain from exercising jurisdiction to grant declaratory relief in cases involving rights and duties thereunder.