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Heart of Atlanta Motel v. United States

Supreme Court of the United States · 1964 · Constitutional Law

Constitutional LawCommerce ClauseCivil Rights Act of 1964public accommodationsracial discriminationCommerce ClauseTitle IICivil Rights Act of 1964

Facts

Heart of Atlanta Motel owned and operated a 216-room motel in Atlanta that was readily accessible to interstate highways and actively solicited out-of-state business through national advertising, billboards, and convention trade. About 75% of its registered guests were from out of state. Before the Civil Rights Act of 1964, the motel followed a practice of refusing to rent rooms to Negroes and alleged that it intended to continue that policy. It was admitted that the motel fell within § 201(a) and that it refused lodging to transient Negroes because of race.

Issue

Whether Title II of the Civil Rights Act of 1964, as applied to a motel serving interstate travelers and refusing rooms to Negro guests because of race, was a constitutional exercise of Congress's power under the Commerce Clause. The case also presented whether such application violated the Fifth or Thirteenth Amendments.

Rule

Under the Commerce Clause, Congress may regulate commerce that concerns more than one state and has a real and substantial relation to the national interest, including local activities that substantially and harmfully affect interstate commerce. Where Congress had a rational basis for finding that racial discrimination by motels affects interstate commerce, and the means chosen to eliminate that evil are reasonable and appropriate, Title II is constitutional as applied.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lakeshore Suites operates a 140-room motel near the junction of I-90 and I-94 in Chicago, Illinois. It advertises in regional travel magazines, books rooms online for travelers nationwide, and about 70% of its guests list home addresses outside Illinois. The owner refuses to rent rooms to Black travelers.

If Congress applies a federal public-accommodations law to prohibit this policy, which is the strongest basis for upholding the law as applied to the motel?

Explanation. The majority held that Congress may prohibit racial discrimination by a motel serving interstate travelers under the Commerce Clause. Even if the business is locally operated, Congress may regulate local incidents of interstate commerce when they substantially affect interstate commerce. The key questions are whether Congress had a rational basis for finding the discrimination affected commerce and whether the means chosen were reasonable and appropriate.