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Heart of Atlanta Motel v. United States
[379 U.S. 241]
Warren Court,  Decided 9-0,  12/14/1964
Read the actual decision


Chief Justice Earl WarrenThis case was the landmark decision for the right of Congress, under the Commerce Clause of the Constitution, to prohibit discrimination in public accommodations. As such, it was the earliest test of the constitutionality of applying the Civil Rights Act of 1964 to private endeavors, and opened the way for further regulation of business in the interest of an ever-broadening view of civil rights.

The Heart of Atlanta Motel, which primarily served transients, routinely discriminated against blacks by refusing them service, even after the enactment of Title II of the Civil Rights Act of 1964, which prohibited such actions. The owners of the motel claimed that the Act violated their Fifth Amendment right not to be deprived of their property without just compensation (in this case the free use of their property), and their Thirteenth Amendment right not to be subjected to involuntary servitude. They also claimed that Congress had exceeded its authority under the Commerce Clause.

Congress had cited the Commerce Clause as substantiation for the Civil Rights Act because, at that time, the standing interpretation of the Fourteenth Amendment held that it did not apply to private enterprise, an interpretation surviving from the Civil Rights Cases of 1883.

In unanimously affirming the constitutionality of Title II, the Court cited a long series of decisions, stretching back to the early nineteenth century, which confirmed Congress' power to regulate interstate commerce under the Commerce Clause. It further stipulated that, even though an enterprise may serve entirely local customers, the fact that it may buy supplies through interstate commerce is enough to subject it to Congress' regulatory power under the Clause.

In addition, it suggested that Congress could use its "national police power" to regulate both interstate and intrastate activities that affected commerce, when necessary to legislate against moral wrongs. In effect, the Court has thus given Congress carte blanche to regulate all business under the Commerce Clause for any cause which it deems to be in the national interest.

Opening the way for the looser interpretation of the Fourteenth later found in Griggs v. Duke Power (1971), Justices William O. Douglas and Arthur Goldberg suggested that the Fourteenth would have been an acceptable basis for deciding this case as well.


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     ... or on subject Civil Rights    Find other Documents
     ... or on subject Commerce    Find other Documents

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Other decisions pertaining to Civil Rights:

Barrows v. Jackson    [346 U.S. 249 (1905)]  Warren Court
Batson v. Kentucky    [476 U.S. 79 (1986)]  Burger Court
Bernel v. Fainter    [104 S.Ct. 2312 (1984) (1905)]  Burger Court
Brown v. Board of Education    [349 U.S. 294 (1955)]  Warren Court
Civil Rights Cases    [109 U.S. 3 (1883)]  Waite Court
Craig v. Boren    [429 U.S. 190 (1976)]  Burger Court
Goesaert v. Cleary    [335 U.S. 464 (1905)]  Vinson Court
Griggs v. Duke Power    [401 U.S. 424 (1971)]  Burger Court
Grovey v. Townsend    [295 U.S. 45 (1935)]  Hughes Court
Hoyt v. Florida    [368 U.S. 57 (1961)]  Warren Court
Jones v. Alfred H. Mayer Co.    [392 U.S. 409 (1968)]  Warren Court
Korematsu v. United States    [323 U.S. 214 (1944)]  Stone Court
Plessy v. Ferguson    [163 U.S. 537 (1896)]  Fuller Court
Powell v. Alabama    [287 U.S. 45 (1932)]  Hughes Court
Scott v. Sandford    [60 U.S. 393 (1857)]  Taney Court
Shelly v. Kraemer    [334 U.S. 1 (1948)]  Vinson Court
Smith v. Allwright    [321 U.S. 649 (1944)]  Stone Court
United States v. Cruikshank    [92 U.S. 542 (1876)]  Waite Court
United Steel Workers of America v. Weber    [443 U.S. 193 (1979)]  Burger Court
University of California v. Bakke    [438 U.S. 265 (1978)]  Burger Court

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