Heart of Atlanta Motel v. United States, 379 U.S. 241

Supreme Court of the United States

1964

Chapter

2

Title

Federalism at Work

Page

210

Topic

The Evolution of Commerce Clause Doctrine

Quick Notes

In this a motel in Georgia was accused of racial discrimination for violating the 1964 Civil Rights Act. The motel argued that the law shouldn't apply to them because they weren't engaged in interstate commerce and were therefore beyond the reach of the Interstate Commerce Clause.

Motel was of a purely local character

o         It did not matter that the motel was of a purely  local character because the power of Congress to promote interstate commerce also included the power to regulate the local incidents thereof, including local activities in both the state of origin and destination, which MIGHT have a substantial and harmful effect upon that commerce.

Book Name

Constitutional Law : Stone, Seidman, Sunstein, Tushnet.  ISBN:  978-0-7355-7719-0

Issue

o         Whether Congress can enforce interstate commerce on obstructions that are deemed moral and social wrongs?  Hell Yes.

Procedure

District

o         United States District Court for the Northern District of Georgia ruled that Heart of Atlanta was in violation of the Act.

Supreme

o         Affirmed

Facts

Discussion

Key Phrases

Rules

Pl Heart of Atlanta Motel

Df United States

Party Description

The Heart of Atlanta Motel

o         Located in downtown Atlanta, Georgia.

o         Had 216 rooms.

o         75% of its guest was from out of state (interstate commerce).

 Civil Rights Act of 1964

o         Title II of the 1964 Civil Rights Act that "All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation, as defined in this section, without discrimination or segregation on the ground of race, color, religion, or national origin."

Public Accommodations (def)

o         Place of public accommodation as those whose operations affect commerce.

Declaratory Judgment

o         The Heart of Atlanta Motel sought a declaratory judgment that Title II was unconstitutional.

Power to regulate interstate commerce

o         The Court upheld the statute as a valid exercise of power to regulate interstate commerce.

Court Reliance on the burdens of discrimination in Congressional hearings

o         People have become increasingly mobile with millions of people of all races traveling from State to State;

o         [African Americans] in particular have been the subject of discrimination in transient accommodations, having to travel great distances [obtain security].

o          [African Americans]  often [were] unable to obtain accommodations and [had to stay with] friends overnight,

o         [African Americans] in a special guidebook that told there were to obtain lodging.

Qualitative and Quantitative Effects

o         This testimony indicated a qualitative as well as quantitative effect on interstate travel by Negroes.

o         The former [Qualitative] was the obvious impairment of the [African Americans] traveler's pleasure and convenience that resulted when he continually was uncertain of finding lodging.

o         As for the latter [Quantitative Effect], there was evidence that this uncertainty stemming from racial discrimination had the effect of discouraging travel on the part of a substantial portion of the [African Americans] community.

In relation to Interstate commerce

o         [There] is overwhelming evidence of the disruptive effect that racial discrimination has had on commercial intercourse.

Discrimination Burden Empowers Congress

o         It was this burden which empowered Congress to enact appropriate legislation.

o         Congress was not restricted by the fact that the particular obstruction to interstate commerce with which it was dealing was also deemed a moral and social wrong.

Motel was of a purely local character

o         It did not matter that the motel was of a purely  local character because the power of Congress to promote interstate commerce also included the power to regulate the local incidents thereof, including local activities in both the state of origin and destination, which MIGHT have a substantial and harmful effect upon that commerce.

Obstructions of Commerce

o         Obstructions of Commerce are within the sound discretions of Congress.

Caveat

o         Congresss MEANS chosen by it must be reasonably adapted to the END permitted by the Constitution.

AFFIRMED

Rules

Civil Rights Act of 1964

o         Provides that: All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation, as defined in this section, without discrimination or segregation on the ground of race, color, religion, or national origin.

Intrastate which affect interstate commerce

o         The power of Congress over interstate commerce is not confined to the regulation of commerce among the states.

o         It extends to those activities intrastate which so affect interstate commerce or the exercise of the power of Congress over it as to make regulation of them appropriate means to the attainment of a legitimate end, the exercise of the granted power of Congress to regulate interstate commerce

Class Notes