Heart of Atlanta Motel v. U.S. (379 U.S. 241, 1964)
Private Discrimination
The Issue
Under the Constitution, can Congress pass a law preventing private businesses from discriminating against people because of their race or color?
What's at Stake?
Whether Americans can be discriminated against in their daily life.
Background
This case hinged on whether the federal government has the power to make private discrimination a crime.
This was not the first time the Court had considered the issue. In the 1880s, the Civil Rights cases also asked whether the federal government could outlaw private discrimination under the Constitution.
The Constitution reserves certain powers to the states and lists certain powers as belonging to the national government. The Fourteenth Amendment to the Constitution gave some new powers to the federal government. The amendment was ratified [approved] in 1868. It was one of the most important changes in the law enacted in the Reconstruction period after the Civil War. (Reconstruction lasted from the end of the Civil War in 1865 to 1877. During Reconstruction, the federal government tried to rebuild the Southern states on a foundation of equality.)
The Fourteenth Amendment prohibited discrimination by states, thus limiting their power, but what about discrimination by private businesses like restaurants and hotels? Congress passed a law in 1875 that outlawed such discrimination. The Civil Rights Act of 1875 made it a crime to deny to anyone the "full and equal enjoyment" of railways and other transportation. It also required equal treatment in hotels, theaters and other places of public amusement.
Some businesses refused to serve African Americans. Their cases went all the way to the Supreme Court. In the Civil Rights Cases (1883), the Court held that the Fourteenth Amendment did not give Congress the power to outlaw private discrimination. Congress could pass a law forbidding states to discriminate, and the states could pass laws forbidding private businesses from discriminating, but the federal government itself did not have the authority to forbid private businesses from discriminating.
Facts
In Heart of Atlanta Motel v. United States, the Court was faced with a very similar issue. Congress had outlawed discrimination in public accommodations (hotels, restaurants, etc.) in the Civil Rights Act of 1964. This law was much like the 1875 law. As in the case of the earlier statute, some businesses refused to serve African Americans. One of these was a motel owner in Atlanta. His business served mostly interstate travelers. He claimed that Congress had exceeded its authority under the Commerce Clause by regulating a local private business. He also claimed that the law should be declared invalid under the Due Process Clause of the Fifth Amendment.
The Decision
The Supreme Court decision was unanimous. The Court upheld the law. Justice Tom Clark wrote for the Court. He pointed out that the Court had long upheld Congress's power to regulate interstate commerce under the Commerce Clause. One of the cases he cited was Gibbons v. Ogden, decided in 1824.Beginning with the New Deal in the 1930s, Congress often claimed authority to pass legislation under the Commerce Clause, and the Court generally upheld that power. In this case, Clark said that Congress could regulate both interstate commerce and activities within a state as part of its national "police power" to outlaw moral wrongs.
The Impact of the Decision
With the law upheld, a very powerful legal tool was available to enforce equal treatment. Over the years, there have been fewer and fewer instances of overt [direct] racial discrimination in public accommodations.
Find Out
1. Research the Civil Rights Cases. Explain how and why the decision there was different from the decision in Heart of Atlanta.
2. In another 1964 case, Katzenbach v. McClung, the Court upheld the Civil Rights Act of 1964 even for a small local restaurant (Ollie's Barbeque). The Court held that even though the restaurant's customers were local, it bought much of its supplies through interstate commerce, and that was enough to bring it under the Commerce Clause. Compare this with the Supreme Court's reasoning in such earlier cases as Schechter Poultry Corporation v. United States (1935) and National Labor Relations Board v. Jones and Laughlin Steel Corp. (1937). Do cases like Heart of Atlanta and Katzenbach show the continuation of a trend in how the Court thinks about the Commerce Clause?