Heart of Atlanta Motel, Inc. v. United States

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Heart of Atlanta Motel, Inc. v. United States
Northern District of Georgia affirmed.
Court membership
Chief Justice Earl Warren Associate Justices John M. Harlan II William J. Brennan Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Clark, joined by Warren, Douglas, Harlan, Brennan, Stewart, White, Goldberg
Concurrence	Black
Concurrence	Douglas
Concurrence	Goldberg
Laws applied
Title II of the Civil Rights Act of 1964

Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), was a

In addition, Rolleston maintained that it 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, he contended that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to African Americans, thereby violating his Thirteenth Amendment rights. Rolleston noted that in 1944 the Fifth Circuit Court of Appeals for the United States held that even if acts committed in involuntary servitude are compensated, it still violates the Thirteenth Amendment.^[4]

Rolleston maintained throughout his argument that the Constitution should be interpreted as it was at the time of its creation and as the

In response, Archibald Cox, the Solicitor General for the United States, countered that the restrictions requiring adequate accommodation for African Americans were unquestionably related to interstate travel and that Congress, under the Constitution's Commerce Clause, certainly had the power to address such a matter in law. Cox stated that racial discrimination in inns and restaurants “constitute[s] a source of burden or obstruction to interstate commerce.”^[4] He brought up multiple examples in which protests over racial discrimination, some in regards to public accommodations and some with broader scopes, intensely affected the economy of certain areas. One of the prime examples was Birmingham, Alabama in the spring of 1963, during which department and downtown store sales dropped dramatically in the area and the amount of business failure rivaled the rates of the Great Depression.^[4] Cox also mentioned that areas that do not practice equal opportunity are often overlooked by companies that seek commercial and industrial expansion due to the possibility of demonstrations. He used Little Rock, Arkansas to exemplify this point, as business expansion fell by over 50 million dollars in the two years it experienced high racial tensions.^[4]

Cox also highlighted how discrimination by hotels and motels hinders interstate travel by limiting the availability of accommodations for travelers. He described the impediment discrimination imposes with a hypothetical road trip:^[4]

On a motor trip between Washington D.C. and Miami, Florida, the average distance that was found between accommodations of reasonable quality open to Negroes was 141 miles. And when we think of the frequency by such we go by other hotels and motels open to everyone, the significance of a three or four-hour drive between the hope of accommodation is very significant indeed. — Archibald Cox

He further argued that the Fifth Amendment does not forbid reasonable regulation of interstate commerce and that such incidental damage did not constitute the "taking" of property without just compensation or due process of law. He emphasized that the courts have consistently sustained cases that strengthen anti-discrimination measures.^[4] Lastly, he asserted that the Thirteenth Amendment applies primarily to slavery and the removal of widespread disabilities associated with it and so it undoubtedly would not place issues of racial discrimination in public accommodations beyond the reach of federal and state law:^[4]

But surely it would turn the world quite upside down for anyone to seriously suggest that the Thirteenth Amendment was intended to prohibit either Congress or the state governments from guaranteeing Negroes equality of treatment in places of public accommodation. — Archibald Cox

On July 22 1964, the three judge panel for the United States District Court for the Northern District of Georgia ruled in favor of the United States. It issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination when providing services or goods to guests or the general public on its premises.^[5] The case was combined with the case of the future Governor of Georgia Lester Maddox, regarding his Pickrick restaurant and his refusal to serve African Americans.^[6]

The plaintiffs appealed the decision to the U.S. Supreme Court, which unanimously upheld the District Court ruling. The opinion of the court, announced on December 14, 1964, was delivered by Justice Tom C. Clark, with concurring opinions by Justices Arthur Goldberg, Hugo Black, and William O. Douglas.

The ruling held that Congress acted well within its authority under the 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 difficult to conceive that such an amendment might 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 Georgia highways, the Court found that the business clearly affected interstate commerce. Accordingly, it upheld the permanent injunction issued by the district court and required the Heart of Atlanta Motel to receive business from the clientele of all ethnicities.

Heart of Atlanta Motel, Inc. v. United States has been cited in at least 690 other case decisions since its ruling, including multiple other Supreme Court cases.^[7] In the 1997 case Camps Newfound/Owatonna, Inc. v. Town of Harrison a summer camp in Maine that mainly serviced out-of-state residents fought against a state tax exemption statute that favored organizations that serviced state residents.^{[8][non-primary source needed]} The courts compared out-of-state campers staying at a summer camp to out-of-state residents occupying a hotel, deeming the camp a participant in interstate commerce.^[9] Another example is the 1966 case United States v. Guest, in which the courts ruled, due to the conspiratorial murder of Lt. Col. Lemuel Penn while he was traveling home, that forcefully depriving someone's right to travel is unconstitutional.^[10]

• Constantine v Imperial Hotels Ltd
• Katzenbach v. McClung
• List of United States Supreme Court cases, volume 379
• The Negro Motorist Green Book

External links

Wikisource has original text related to this article:

Heart of Atlanta Motel, Inc. v. United States

• Text of Heart of Atlanta Motel v. United States, 379 U.S. 241 (1964) is available from: Findlaw Justia Library of Congress Oyez (oral argument audio) University of Missouri Kansas City
• Heart of Atlanta – misc photos
• Heart of Atlanta/Pickrick trial, Civil Rights Digital Library