Politics & International Relations

Heart of Atlanta Motel v. United States

"Heart of Atlanta Motel v. United States" was a landmark Supreme Court case in 1964 that upheld the constitutionality of the Civil Rights Act of 1964. The case centered on the motel's refusal to accommodate African American guests, arguing that the law violated its rights. The Court ruled that Congress had the authority to regulate private businesses under the Commerce Clause to prevent racial discrimination.

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6 Key excerpts on "Heart of Atlanta Motel v. United States"

  • Book cover image for: Student′s Guide to the Supreme Court
    • Bruce J. Schulman(Author)
    • 2010(Publication Date)
    • CQ Press
      (Publisher)
    A – Z Heart of Atlanta Motel v. United States (1964) ★ 147 ★ Basis of the Case The case of Heart of Atlanta Motel v. United States (1964) involved a motel in downtown Atlanta that refused to serve blacks in defiance of the new federal civil rights law. The motel owner charged that Congress had exceeded its authority under the commerce clause when it enacted Title II. He also claimed that Congress denied him his Fifth Amendment rights by depriving him of the freedom to choose his customers. The Court’s Ruling Writing for a unanimous Court, Justice Tom C. Clark rejected the motel owner’s argument. Clark noted that the motel was accessible to interstate travelers, that it sought out-of-state business by advertising in national publications, and that 75 percent of its guests were interstate travelers. 148 ★ Heart of Atlanta Motel v. United States (1964) A – Z ★ Moreton Rolleston Jr., owner of the Heart of Atlanta Motel, challenged the constitutionality of the Civil Rights Act of 1964. In Heart of Atlanta Motel v. United States (1964), the Supreme Court unanimously upheld the law. The Court declared that Congress may use its powers to regulate interstate commerce to prohibit racial discrimination in privately owned accommodations. (© Bettmann, Corbis) Landmark Decision Highlights: Heart of Atlanta Motel v. United States (1964) Issue: Whether Congress, by passing the 1964 Civil Rights Act, exceeded its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers Opinion: The Supreme Court held that the Commerce Clause allowed Congress to regulate local aspects of commerce, and that the Civil Right Act of 1964 was constitutional. The Court concluded that places of public accommodation had no right to select guests as they saw fit, free from governmental regulation.
  • Book cover image for: Civil Rights in Public Service
    • Phillip J. Cooper(Author)
    • 2016(Publication Date)
    • Routledge
      (Publisher)
    It is difficult for many Americans to believe decades after the fact, but the effort to enact the Civil Rights Act of 1964 was a hard-fought battle in which, at times, the outcome was far from clear. And even after the law went into effect, there were challenges to the constitutional validity of the Act. Cases from Atlanta and Birmingham reached the Supreme Court.
    Heart of Atlanta Motel v. United States 379 U.S. 241 (1964)
    INTRODUCTION: This is one of the two cases brought to test the Article I authority of Congress to enact the Civil Rights Act of 1964. The fact that the decision of the Supreme Court in the Civil Rights Cases had never been overturned meant that Congress had to rely on the commerce power rather than simply the enforcement clause of the Fourteenth Amendment for the authority to support the new statute. The challengers focused on the claim that there was no commerce clause justification for the law.
    Justice Clark wrote the opinion for the Court.
    This is a declaratory judgment action … attacking the constitutionality of Title II of the Civil Rights Act of 1964… A three-judge court … sustained the validity of the Act…. We affirm the judgment.
    [T]‌he Heart of Atlanta Motel … has 216 rooms available to transient guests. The motel is located on Courtland Street, two blocks from downtown Peachtree Street. It is readily accessible to interstate highways 75 and 85 and state highways 23 and 41. Appellant solicits patronage from outside the State of Georgia through various national advertising media, including magazines of national circulation; it maintains over 50 billboards and highway signs within the State, soliciting patronage for the motel; it accepts convention trade from outside Georgia and approximately 75% of its registered guests are from out of State. Prior to passage of the Act the motel had followed a practice of refusing to rent rooms to Negroes, and it alleged that it intended to continue to do so. In an effort to perpetuate that policy this suit was filed.…
  • Book cover image for: A History of Civil Rights Through Legislation: Constitutional Amendments, Laws, Supreme Court Decisions & Key Foreign Policy Acts
    • U.S. Government, U.S. Supreme Court, U.S. Congress(Authors)
    • 2017(Publication Date)

    Heart of Atlanta Motel, Inc. v. United States

    (1964)
    Table of Contents
    CASE SYLLABUS
    OPINION OF THE COURT
    CONCURRING OPINIONS
    BLACK
    DOUGLAS
    GOLDBERG
    Passage contains an image

    CASE SYLLABUS

    Table of Contents
    United States Supreme Court 379 U.S. 241 HEART OF ATLANTA MOTEL, INC. v. UNITED STATES United States District Court for the Northern District of Georgia No. 515 Argued: October 5, 1964 –- Decided: December 14, 1964
    Moreton Rolleston, Jr., Atlanta, Ga., for appellant. Archibald Cox, Sol. Gen., for appellees. Mr. Justice CLARK delivered the opinion of the Court
    This is a declaratory judgment action, 28 U.S.C. § 2201 and § 2202 (1958 ed.) attacking the constitutionality of Title II of the Civil Rights Act of 1964, 78 Stat. 241, 241. In addition to declaratory relief the complaint sought an injunction restraining the enforcement of the Act and damages against appellees based on allegedly resulting injury in the event compliance was required. Appellees counterclaimed for enforcement under § 206(a) of the Act and asked for a three-judge district court under § 206(b). A three-judge court, empaneled under § 206(b) as well as 28 U.S.C. § 2282 (1958 ed.) sustained the validity of the Act and issued a permanent injunction on appellees' counterclaim restraining appellant from continuing to violate the Act which remains in effect on order of Mr. Justice BLACK, 85 S.Ct. 1. We affirm the judgment.
    Passage contains an image

    OPINION OF THE COURT

    Table of Contents
    1. The Factual Background and Contentions of the Parties.
    The case comes here on admissions and stipulated facts. Appellant owns and operates the Heart of Atlanta Motel which has 216 rooms available to transient guests. The motel is located on Courtland Street, two blocks from downtown Peachtree Street. It is readily accessible to interstate highways 75 and 85 and state highways 23 and 41. Appellant solicits patronage from outside the State of Georgia through various national advertising media, including magazines of national circulation; it mainains over 50 billboards and highway signs within the State, soliciting patronage for the motel; it accepts convention trade from outside Georgia and approximately 75% of its registered guests are from out of State. Prior to passage of the Act the motel had followed a practice of refusing to rent rooms to Negroes, and it alleged that it intended to continue to do so. In an effort to perpetuate that policy this suit was filed.
  • Book cover image for: Federalism and Subsidiarity
    eBook - ePub
    • James E. Fleming, Jacob T Levy, James E. Fleming, Jacob T Levy(Authors)
    • 2014(Publication Date)
    • NYU Press
      (Publisher)
    72 If African Americans could not readily find lodgings, their capacity to participate in commercial activities across the country was greatly impaired. VAWA’s record seemed to meet that standard; Congress received evidence of the nationwide economic impacts of injuries to women in terms of dollars lost in the workplace and dollars spent on the health care system, as well as the degree to which women tried to organize wage work to avoid heightening the risk of assaults.
    The symbolism of opening an avenue to the federal courts was broader than the practical effect. Although federal judges had predicated opposition to VAWA’s civil rights remedy in part on floodgate arguments, fewer than fifty federal cases relying on VAWA’s civil rights remedy resulted in published decisions between 1994 and 2000, when the Supreme Court heard the constitutional challenge.73 On the other hand, the Morrison
  • Book cover image for: New York Hotel Experience
    eBook - PDF

    New York Hotel Experience

    Cultural and Societal Impacts of an American Invention

    In the case of minorities, it is therefore even more important to look closely at the roles which hotels performed for these ethnic communities and how they impacted the communities’ culture. Hotels catering to groups on the margin were under more stress and scrutiny to fulfill their roles successfully as sanctuary, retreat, and palace of the public. As I will show with the Hotel Theresa, the discrimination existing in mainstream hotels, resorts, and entertainment halls did 4 The concept behind declaring the act unconstitutional was that the federal government did not have the right to limit the individual rights of a person. Thus the private status of the innkeeper was accepted and protected (Sandoval-Strausz 301). 5 The Act outlawed discrimination in “any inn, hotel, motel … any restaurant, cafeteria, lunchroom, lunchcounter, soda fountain … any motion picture house, theater, concert hall, sports arena, stadium or other place of exhibition or entertainment” (Sandoval-Strausz 307). Because the Civil Rights Act of 1964 so closely resembled the one of 1875, it also needed to prove its constitutionality. This was largely achieved in the case of Heart of Atlanta Motel vs. United States, where the Supreme Court Justices used the law of hospitality and the need to protect travelers to affirm the constitutionality of the Civil Rights Act. Discrimination against minorities in the 1960s would have “a far greater impact upon the Nation’s commerce than such practices had upon the economy of another day” (Sandoval-Strausz 309). 218 | N EW Y ORK H OTEL E XPERIENCE not mean that African-Americans were excluded from the institution hotel in general. To fill the gap, an alternative hotel-network developed that catered specifically to African-Americans. 6 Since the middle of the nineteenth century it became a “patriotic exercise” (Armstead, “Revisiting Hotels” 151) to tour the country and visit historic sites across America, in short to travel America as a tourist.
  • Book cover image for: Signposts
    eBook - ePub

    Signposts

    New Directions in Southern Legal History

    38
    The Supreme Court was only marginally less dismissive in its treatment of the various other possible constitutional bases for the right-to-discriminate claim. It referenced and summarily rejected all claims that Title II infringed constitutional protections of property or liberty.39 Justice Black did little to hide his irritation with these arguments, which he characterized as claiming “that the broad power of Congress to enact laws deemed necessary and proper to regulate and protect interstate commerce is practically nullified by the negative constitutional commands that no person shall be deprived of ‘life, liberty, or property, without due process of law’ and that private property shall not be ‘taken’ for public use without just compensation.” There was, however, simply no basis to challenge Title II on either due process or takings grounds. His assessment of the takings argument could have been used for practically every judicial evaluation of the right to discriminate during the civil rights era: it “does not even come close.”40
    Debating the Right to Discriminate
    Regardless of whether they had any chance of being recognized in court, claims of a right to discriminate could be heard whenever government attempted to enforce a nondiscrimination norm on reluctant citizens. As civil rights activists found courts and legislatures increasingly receptive to their demands for government-enforced protection against discrimination in all walks of life, opponents mobilized an array of arguments. They praised the values and traditions of white supremacy. When it was the federal government demanding nondiscrimination, they sang the song of states’ rights. And with increasing prominence over the course of the civil rights movement, they turned to the argument that antidiscrimination policy threatened their individual liberties. This argument was never regarded as a serious one in the courts, but it was a formidable one in extrajudicial contexts.
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