In 1964, the heart of Atlanta Motel found itself at the heart of a landmark civil rights dispute. In Heart of Atlanta Motel v. United States, the United States Supreme Court established a foundation for the use of Congress's Commerce Clause powers to protect civil rights. Congress enacted the Civil Rights Act of 1964 to prohibit discrimination on the basis of race and any place of public accommodation.
A place of public accommodation was defined to include, among other things, motels and restaurants if their operations substantially affect interstate commerce. The heart of Atlanta Motel was located in its namesake city. The motel advertised in national media, it was situated conveniently next to interstate highways, and approximately 75% of its business came from out-of-state guests.
The motel also practiced a policy of of refusing to rent rooms to African Americans. The motel brought a lawsuit against the United States government seeking a declaratory judgment that Congress had exceeded its constitutional authority by enacting the Civil Rights Act. The motel also alleged that the act violated its due process rights by depriving it of the right to select its customers and operate its business as it wished. A three-judge district court panel upheld the Civil Rights Act as constitutional under the Commerce Clause and prohibited the motel from discriminating against African Americans. On direct appeal, the issue before the Supreme Court was whether Congress can prohibit racial discrimination by places of public accommodation using its Commerce Clause authority.
In an opinion by Justice Clark, the court held that Congress can enact laws that prevent racially discriminatory policies in hotels serving interstate travelers because these policies substantially affect interstate commerce. The court observed that Congress's power to regulate interstate commerce includes the power to regulate local incidents of commerce that have a substantial relation to the interstate flow of goods. As a result, the court reasoned that Congress has the power to remove local obstructions and restraints to interstate commerce. The court also reviewed the Congressional Record for the Civil Rights Act.
The record established that racial discrimination has a disruptive effect on interstate travel by substantially discouraging travel by African Americans. With no place to stay while traveling, African Americans weren't able to move freely from state to state, and this created a drag on interstate commerce. Therefore, the court held that the Civil Rights Act, as applied to places of public accommodation that serve interstate travelers, was a valid exercise of Congress's Commerce Clause authority.
The court affirmed the district court's order in joining the motel from discriminating on the basis of race. In a concurring opinion, Justice Black agreed that Congress had the power to regulate the motel's activities under the Commerce Clause. Noting that the motel was a large establishment that advertised extensively on interstate highways, Black concluded that the motel's racial discrimination policies had a great impact on interstate commerce. Additionally, Black rejected the motel's argument that the act violated its due process rights.
For one thing, regulating the use of private property isn't a constitutional taking under the Fifth Amendment. Additionally, the Fourteenth Amendment, which was adopted to prohibit discrimination, can't be used to strip Congress of its power to protect African Americans from further discrimination. Justice Douglas, in another concurring opinion, argued that the court shouldn't have rested its decision on the Commerce Clause. By relying solely on Congress's authority to regulate interstate commerce, the majority implied that an impact on interstate commerce is a prerequisite for protection against discrimination.
But for Douglas, this prerequisite was unnecessary. Instead, he argued that a stronger and broader basis for Congress's authority could be found under Section 5 of the 14th Amendment. Section 5 grants Congress the power to enforce, by appropriate legislation, the right of all persons to equal protection of the law. Finally, Justice Goldberg, also concurring, reasoned that the majority opinion should rest on both the 14th Amendment and the Commerce Clause, rather than on one or the other. For Goldberg, Congress had clear authority under both provisions to enact the Civil Rights Act.
Part of Atlanta Motel v. United States was a landmark civil rights decision that allowed Congress to use its Commerce Clause powers to combat racial discrimination.