Heart of Atlanta Motel, Inc. v. United States
379 U.S. 241 (1964)
A 216-room motel near the interstate that refused Black guests
- In one lineEn una línea
- Congress may use the Commerce Clause to ban racial discrimination by local businesses that serve interstate travelers.El Congreso puede usar la Commerce Clause para prohibir la discriminación racial en negocios locales que atienden a viajeros interestatales.
- RuleRegla
- If Congress has a rational basis for finding that an activity affects interstate commerce, it may regulate it under the Commerce Clause, whatever the moral motive behind the statute.
- Why this case is herePor qué está aquí este caso
- Garza's example of how far the Commerce Clause reaches: Congress can regulate local businesses whose operations affect interstate commerce, even for a moral purpose.
- Procedural posturePostura procesal
- The motel sued to declare Title II of the Civil Rights Act of 1964 unconstitutional; a three-judge district court upheld the Act and enjoined the motel from discriminating; direct appeal to the Supreme Court, which affirmed.
Facts
The Heart of Atlanta Motel, located near Interstates 75 and 85, advertised nationally and drew most of its guests from other states. It refused to rent rooms to Black customers and intended to continue after the Civil Rights Act of 1964 took effect.
Procedural posture
The motel sued for a declaration that Title II (public accommodations) was unconstitutional and an injunction against its enforcement; the United States counterclaimed. A three-judge district court upheld the Act and enjoined the motel. The motel appealed directly to the Supreme Court, which affirmed.
Issue
Whether Congress had power under the Commerce Clause to prohibit racial discrimination in places of public accommodation that serve interstate travelers.
Holding
Yes. Title II is a valid exercise of the commerce power as applied to the motel.
Reasoning
Congress heard extensive evidence that discrimination in lodging obstructed interstate travel by Black Americans and burdened commerce. The power to regulate commerce includes the power to regulate local activities that have a substantial and harmful effect on it, and the test is only whether Congress had a rational basis for its finding and chose reasonable means. That the problem was also moral does not remove it from the commerce power. The Fifth Amendment takings and Thirteenth Amendment arguments were rejected.
Rule (own words)
Local conduct that affects interstate commerce is within Congress’s reach, and courts ask only whether Congress acted rationally.
What-ifs
- Compare United States v. Lopez (1995): guns near schools were not economic activity, so the commerce power did not reach them; the motel’s lodging business was.
- If the motel served only locals, the commerce link would be weaker, though Katzenbach v. McClung (restaurant buying food that crossed state lines) shows the link can be indirect.
Likely follow-upsRepreguntas probables
Why the Commerce Clause and not the Fourteenth Amendment?
What facts connected the motel to interstate commerce?
Does the moral purpose matter?
Say the answer out loud before revealing each part. Rate yourself honestly; the case comes back sooner when you miss.Di la respuesta en voz alta antes de revelar cada parte. Califícate con honestidad; el caso vuelve antes si fallas.
Panic kit: “Could you repeat the question, please?” · “Let me make sure I have the facts right: …” · “I'm not certain, but I'd argue … because …”Kit de pánico: “Could you repeat the question, please?” · “Let me make sure I have the facts right: …” · “I'm not certain, but I'd argue … because …”