Summary of Heart of Atlanta Motel v. United States (1964)
Relevant Facts: Heart of Atlanta Motel is a 216 room place just of Peachtree Street in the ATL. It refused to accommodate African-Americans. Conceding it fell within the statute, it sought an order invalidating Title II as applied to its business.
Issue: Under constitutional law, must a motel, which falls under desegregation requirements of the Civil Rights Act of 1964, comply with the enacted federal statute or may it interpose the fact the Act itself is unconstitutional in that it is an abuse of the commerce clause of the Constitution in dealing with a hotel which is solely local in nature?
Holding: Yes. Since Congress has the power to regulate commerce, and interstate travel is a part of commerce, and a motel could conceivably be a part of commerce/travel, it is under the umbrella of the commerce clause and subsequently any Act (Title II) passed by Congress.
Court’s Rationale/Reasoning: The originalist approach to analyzing the testimony and evidence brought forth when the Act was up for debate in Congress suggests there was indeed a pressing issue regarding segregation of blacks being a hindrance on interstate commerce and travel, which were grouped together by the Act. The Court also recognized the importance of a moral matter at the same time, but insisted this decision was in the interest of commerce.
The term “intercourse” as used in Gibbons (textual) back in 1824 included the movement of persons from state to state. Since hotels, inns and the like were covered under the Act as being places where travel and commerce happened to come through on a regular basis, the motel in Atlanta was not exempt from abiding by this law.
Rule: Under Title II, “any inn, hotel, motel, or other establishment which provides lodging to transient guests” affects commerce per se.
Article 1, § 8, clause 3 (commerce clause): Article 1, Section 8, Clause 3 of the United States Constitution empowers the United States Congress “To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes”.
Important Dicta: Aside from the decision, important info…
Concurring: Justice Douglas wrote the decision should not just rest solely on the commerce clause itself, b/c racism itself is a more important issue Than the shipping of goods across state and international lines, and this case should not be put in that category.