Heart of Atlanta Motel v. United States
Encyclopedia
Heart of Atlanta Motel Inc. v. United States, 379 U.S. 241
(1964),
was a landmark United States Supreme Court
case holding that the U.S. Congress could use the Constitution's Commerce Clause
power to force private businesses to abide by the Civil Rights Act of 1964.
, the landmark piece of civil rights
legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875
. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation
, a system of racial separation which, while in name providing for "separate but equal
" treatment of both white and black Americans
, in truth perpetuated inferior accommodation, services, and treatment for black Americans.
During the mid-twentieth century, partly as a result of cases such as Powell v. Alabama
, 287 U.S. 45 (1932); Smith v. Allwright
, 321 U.S. 649 (1944); Shelley v. Kraemer
, 334 U.S. 1 (1948); Sweatt v. Painter
, 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents
, 339 U.S. 637 (1950); NAACP v. Alabama
, 357 U.S. 449 (1958); Boynton v. Virginia
, 364 U.S. 454 (1960) and probably the most famous, Brown v. Board of Education of Topeka
, 347 U.S. 483 (1954), the tide against segregation began to turn. However, segregation remained in full effect into the 1960s in parts of the southern United States
, where the Heart of Atlanta Motel was located, despite these decisions.
' control of interstate commerce.
The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia
, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act violated his Fifth Amendment
rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process
of law
and just compensation. Finally, the owner argued that Congress had placed him in a position of involuntary servitude
by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment
rights.
In response, the United States countered that the restrictions in adequate accommodation for black Americans severely interfered with interstate travel, and that Congress, under the United States Constitution
's Commerce clause, was certainly within its power to address such matters. Moreover, they argued, the Fifth Amendment
does not forbid reasonable regulation of interstate commerce and such incidental damage did not constitute the "taking" of property without just compensation or due process of law. Third, they argued that the Thirteenth Amendment applied primarily to slavery
and the removal of widespread disabilities associated with it; in such kind, the Amendment certainly would not place issues of racial discrimination in public accommodations beyond the reach of Federal
and state
law.
The District court ruled in favor of the United States and issued a permanent injunction
requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination in terms of the goods or services that it offered to guests or the general public upon its premises. The owner of the motel was Attorney Moreton Rolleston. This case was combined with the case of the future Governor of Georgia Lester Maddox
concerning his Pickrick restaurant and his case to refuse to serve blacks.
, with concurring opinions by Justice Arthur Goldberg
, Justice Hugo Black
, and Justice William O. Douglas
.
The Court held that Congress acted well within its jurisdiction of the Interstate Commerce clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the Court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it hard to conceive that such an Amendment might possibly be applicable in restraining civil rights legislation
. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75
and 85
as well as two major U.S. Highways, the Court found that the business clearly affected interstate commerce. As such, it therefore upheld the permanent injunction issued by the District Court, and required the Heart of Atlanta Motel to receive business from clientele of all races.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1964),
was a landmark United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case holding that the U.S. Congress could use the Constitution's Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
power to force private businesses to abide by the Civil Rights Act of 1964.
Background
This important case represented an immediate challenge to the Civil Rights Act of 1964Civil Rights Act of 1964
The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that outlawed major forms of discrimination against African Americans and women, including racial segregation...
, the landmark piece of civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875
Civil Rights Act of 1875
The Civil Rights Act of 1875 was a United States federal law proposed by Senator Charles Sumner and Representative Benjamin F. Butler in 1870...
. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
, a system of racial separation which, while in name providing for "separate but equal
Separate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
" treatment of both white and black Americans
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
, in truth perpetuated inferior accommodation, services, and treatment for black Americans.
During the mid-twentieth century, partly as a result of cases such as Powell v. Alabama
Powell v. Alabama
Powell v. Alabama was a United States Supreme Court decision which determined that in a capital trial, the defendant must be given access to counsel upon his or her own request as part of due process.-Background of the case:...
, 287 U.S. 45 (1932); Smith v. Allwright
Smith v. Allwright
Smith v. Allwright , 321 U.S. 649 , was a very important decision of the United States Supreme Court with regard to voting rights and, by extension, racial desegregation. It overturned the Democratic Party's use of all-white primaries in Texas, and other states where the party used the...
, 321 U.S. 649 (1944); Shelley v. Kraemer
Shelley v. Kraemer
Shelley v. Kraemer, 334 U.S. 1 , is a United States Supreme Court case which held that courts could not enforce racial covenants on real estate.-Facts of the case:...
, 334 U.S. 1 (1948); Sweatt v. Painter
Sweatt v. Painter
Sweatt v. Painter, , was a U.S. Supreme Court case that successfully proved lack of equality, in favor of a black applicant, the "separate but equal" doctrine of racial segregation established by the 1896 case Plessy v. Ferguson. The case was also influential in the landmark case of Brown v...
, 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents
McLaurin v. Oklahoma State Regents
McLaurin v. Oklahoma State Regents, 339 U.S. 637 , was a United States Supreme Court case that reversed a lower court decision upholding the efforts of the state-supported University of Oklahoma to adhere to the state law requiring African-Americans to be provided graduate or professional education...
, 339 U.S. 637 (1950); NAACP v. Alabama
NAACP v. Alabama
National Association for the Advancement of Colored People v. Alabama, 357 U.S. 449 , was an important civil rights case brought before the United States Supreme Court....
, 357 U.S. 449 (1958); Boynton v. Virginia
Boynton v. Virginia
Boynton v. Virginia, 364 U.S. 454 was a decision by the Supreme Court of the United States. The case overturned a judgment convicting an African American law student for trespassing by being in a restaurant in a bus terminal which was "whites only." It held that racial segregation in public...
, 364 U.S. 454 (1960) and probably the most famous, Brown v. Board of Education of Topeka
Brown v. Board of Education
Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
, 347 U.S. 483 (1954), the tide against segregation began to turn. However, segregation remained in full effect into the 1960s in parts of the southern United States
Southern United States
The Southern United States—commonly referred to as the American South, Dixie, or simply the South—constitutes a large distinctive area in the southeastern and south-central United States...
, where the Heart of Atlanta Motel was located, despite these decisions.
The case
Passed on July 2, 1964, the Civil Rights Act of 1964 banned racial discrimination in public places, particularly in public accommodations, largely based on CongressUnited States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
' control of interstate commerce.
The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia
Georgia (U.S. state)
Georgia is a state located in the southeastern United States. It was established in 1732, the last of the original Thirteen Colonies. The state is named after King George II of Great Britain. Georgia was the fourth state to ratify the United States Constitution, on January 2, 1788...
, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act violated his Fifth Amendment
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
of law
Law
Law is a system of rules and guidelines which are enforced through social institutions to govern behavior, wherever possible. It shapes politics, economics and society in numerous ways and serves as a social mediator of relations between people. Contract law regulates everything from buying a bus...
and just compensation. Finally, the owner argued that Congress had placed him in a position of involuntary servitude
Involuntary servitude
Involuntary servitude is a United States legal and constitutional term for a person laboring against that person's will to benefit another, under some form of coercion other than the worker's financial needs...
by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment
Thirteenth Amendment to the United States Constitution
The Thirteenth Amendment to the United States Constitution officially abolished and continues to prohibit slavery and involuntary servitude, except as punishment for a crime. It was passed by the Senate on April 8, 1864, passed by the House on January 31, 1865, and adopted on December 6, 1865. On...
rights.
In response, the United States countered that the restrictions in adequate accommodation for black Americans severely interfered with interstate travel, and that Congress, under the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
's Commerce clause, was certainly within its power to address such matters. Moreover, they argued, the Fifth Amendment
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
does not forbid reasonable regulation of interstate commerce and such incidental damage did not constitute the "taking" of property without just compensation or due process of law. Third, they argued that the Thirteenth Amendment applied primarily to slavery
Slavery
Slavery is a system under which people are treated as property to be bought and sold, and are forced to work. Slaves can be held against their will from the time of their capture, purchase or birth, and deprived of the right to leave, to refuse to work, or to demand compensation...
and the removal of widespread disabilities associated with it; in such kind, the Amendment certainly would not place issues of racial discrimination in public accommodations beyond the reach of Federal
Federal government of the United States
The federal government of the United States is the national government of the constitutional republic of fifty states that is the United States of America. The federal government comprises three distinct branches of government: a legislative, an executive and a judiciary. These branches and...
and state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
law.
The District court ruled in favor of the United States and issued a permanent injunction
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination in terms of the goods or services that it offered to guests or the general public upon its premises. The owner of the motel was Attorney Moreton Rolleston. This case was combined with the case of the future Governor of Georgia Lester Maddox
Lester Maddox
Lester Garfield Maddox was an American politician who was the 75th Governor of the U.S. state of Georgia from 1967 to 1971....
concerning his Pickrick restaurant and his case to refuse to serve blacks.
Decision
Announced on December 14, 1964, the opinion of the court was delivered by Justice Tom C. ClarkTom C. Clark
Thomas Campbell Clark was United States Attorney General from 1945 to 1949 and an Associate Justice of the Supreme Court of the United States .- Early life and career :...
, with concurring opinions by Justice Arthur Goldberg
Arthur Goldberg
Arthur Joseph Goldberg was an American statesman and jurist who served as the U.S. Secretary of Labor, Supreme Court Justice and Ambassador to the United Nations.-Early life:...
, Justice Hugo Black
Hugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
, and Justice William O. Douglas
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
.
The Court held that Congress acted well within its jurisdiction of the Interstate Commerce clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the Court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it hard to conceive that such an Amendment might possibly be applicable in restraining civil rights legislation
Legislation
Legislation is law which has been promulgated by a legislature or other governing body, or the process of making it...
. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state, and that it was strategically located near Interstates 75
Interstate 75
Interstate 75 is a major north–south Interstate Highway in the Great Lakes and Southeastern regions of the United States. It travels from State Road 826 and State Road 924 in Hialeah, Florida to Sault Ste. Marie, Michigan, at the Ontario, Canada, border...
and 85
Interstate 85
Interstate 85 is a major interstate highway in the Southeastern United States. Its current southern terminus is at an interchange with Interstate 65 in Montgomery, Alabama; its northern terminus interchanges with Interstate 95 in Petersburg, Virginia, near Richmond...
as well as two major U.S. Highways, the Court found that the business clearly affected interstate commerce. As such, it therefore upheld the permanent injunction issued by the District Court, and required the Heart of Atlanta Motel to receive business from clientele of all races.
See also
- List of United States Supreme Court cases, volume 379
- Katzenbach v. McClungKatzenbach v. McClungKatzenbach v. McClung, 379 U.S. 294 , was a case in which the Supreme Court of the United States held that Congress acted within its power under the Commerce Clause of the United States Constitution in forbidding racial discrimination in restaurants as this was a burden to interstate commerce...