Heart of Atlanta Motel, Inc. v. United States (1964)

Know: Gaining Knowledge

Case

In 1964, President Lyndon B. Johnson signed into law the Civil Rights Act. Title II of the Civil Rights Act banned racial discrimination and segregation in places of public accommodation if their operations affected commerce. This title was based on the Interstate Commerce Clause, in Article I, Section 8 of the Constitution, that states Congress may “regulate commerce… among the several states.” The primary rationale behind Title II was that racial discrimination could harm general economic welfare. The other rationale was that failing to ban racial discrimination violates the Equal Protection Clause under the 14th Amendment, which states that no state shall “deny to any person within its jurisdiction the equal protection of the laws.”

The Heart of Atlanta Motel in Atlanta, Georgia had a history of refusing to serve African-American customers. The Motel was located near two interstate highways. The owner claimed that Title II of the Civil Rights Act was not covered under the Interstate Commerce Clause. The Motel also claimed that the Act violated the 5th Amendment right to due process and the 13th Amendment banning involuntary servitude. The Supreme Court was asked to determine if Title II of the Civil Rights Act exceeded congressional interstate commerce powers.

Decision

In a unanimous decision, the Supreme Court upheld Title II of the Civil Rights Act, noting it fell inside the Interstate Commerce Clause. Justice Tom C. Clark wrote the opinion, deciding because the Motel hosted out of state travelers and fell beside Interstates 75 and 85, that the Motel’s positioning and its customers mean that it was subject to congressional regulation to serve national economic objectives. The Court also denied the Motel’s 5th and 13th Amendment claims. The Court did not acknowledge the second rationale behind the Civil Rights Act under the 14th Amendment’s Equal Protection Clause, and therefore did not uphold that reasoning.

Justice Hugo Black, Justice Arthur Goldberg, and Justice William O. Douglas wrote concurrences to Justice Clark’s opinion. Justice Douglas reasoned under the 14th Amendment’s Equal Protection Clause, claiming that the Motel failed to provide equal protection.

Impact

In United States v. Lopez in 1995, the Supreme Court differed from Heart of Atlanta Motel, Inc. v. United States (1964). Alfonzo Lopez was charged with violating the Gun-Free School Zone Act of 1990, which made carrying a firearm in a school zone a federal crime under the Interstate Commerce Clause. Justice William Rehnquist wrote the majority opinion for the Court, arguing that the commerce powers are not a blank check to Congress, and all commerce can not be understood as interstate commerce. The Court struck down the Gun-Free School Zone Act, and the Court departed from the reasoning established in Heart of Atlanta Motel.

Check Comprehension

Directions: Answer the following multiple-choice questions.

What was the reasoning behind the Civil Rights Act Title II?
1. Interstate Commerce Clause
2. Intrastate Commerce Clause
3. Equal Protection Clause
4. A and C

2. The unanimous decision notes that the Heart of Atlanta Motel…

1. serves out of state travelers.
2. is near Interstates 75 and 85.
3. is subject to jurisdiction under the Interstate Commerce Clause.
4. All of the above.

3. The Supreme Court agreed with the Motel’s 5th and 13th Amendment claims.

1. True
2. False

4. What did Justice Douglas write in his concurrence?

1. Title II is upheld under the Citizenship Clause of the 14th Amendment.
2. Title II is upheld under the Equal Protection Clause of the 14th Amendment.
3. Title II is upheld under the Due Process Clause of the 14th Amendment.
4. Title II is upheld under the Due Process Clause of the 5th Amendment.

5. In the United States v. Lopez (1995), the Supreme Court decided…

1. commerce powers are not a blank check to Congress.
2. all commerce can not be understood as interstate commerce.
3. to strike down the Gun-Free School Zone Act, and the Court departed from the reasoning established in Heart of Atlanta Motel.
4. All of the above.

Learn More

“Heart of Atlanta Motel v. United States.” Britannica, https://www.britannica.com/event/Heart-of-Atlanta-Motel-v-United-States.
“Heart of Atlanta Motel, Inc. v. United States.” Oyez, www.oyez.org/cases/1964/515.
“United States v. Lopez.” Oyez, www.oyez.org/cases/1994/93-1260.

Care: Developing Connections

Think Further

Do you think the Court would have ruled differently if the Heart of Atlanta Motel was not near two highways and did not have out of state travelers?
How can racial discrimination harm interstate commerce?
What reasoning behind Title II of the Civil Rights Act do you find more compelling: the Commerce Clause or the Equal Protection Clause?

See Applications

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Act: Building Skills

Practice Leadership

Since the Court wrote a unanimous opinion in Heart of Atlanta Motel, write a dissent. You may use some of the reasoning in United States v. Lopez. Conclude why Title II may not be covered under the Interstate Commerce Clause. Be sure to note that while the Motel’s conduct was reprehensible, they may have a legal argument.
1964 was a big year in history. Divide the class into groups and have them each research one event from 1964, then give a 2-minute presentation on it to the class. Events may include but are not limited to: Medicare, Freedom Summer, and the 24th Amendment. Note how these events may connect, or show a similar line of reasoning from the Civil Rights Act of 1964.

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