Heart of Atlanta Motel, Inc. v. United States

Background

A Georgia motel owner refused to rent rooms to Black travelers and sued after Title II of the Civil Rights Act of 1964 required equal access. The motel is a large, 216-room business near interstates, widely advertised, and about 75% of its guests came from other states. A three-judge federal court upheld the law and issued an injunction stopping the motel’s racially discriminatory policy, and that judgment was appealed to this Court.

Reasoning

The key question was whether Congress could use its power over interstate commerce to ban racial discrimination by businesses that affect travel and commerce. After reviewing legislative hearings and prior cases, the Court focused on the Commerce Clause and found abundant evidence that racial exclusion impeded interstate travel and commerce. The Justices concluded Congress had a rational basis and chose reasonable means to remove those obstructions, so the Commerce Clause supports applying Title II to this motel. The Court rejected the motel’s claims under the Fifth and Thirteenth Amendments as without merit.

Real world impact

The decision means hotels, motels, and similar businesses that affect interstate travel (or otherwise fit Title II’s definitions) cannot refuse service because of race. It enforces the injunction against the Heart of Atlanta Motel and affirms Congress’s authority to regulate local businesses whose practices, in the aggregate, burden interstate commerce. The Court limited its ruling to the Commerce Clause basis and did not rely on other constitutional grounds in this opinion.

Dissents or concurrances

Several concurring Justices agreed with the result but differed on emphasis: one urged grounding the law on Congress’s power under the Fourteenth Amendment to make coverage broader, while others stressed both commerce power and the Act’s vindication of human dignity.