By passing the Civil Rights Act of 1964, Congress prohibited racial discrimination in places of public accommodation. Congress defined public accommodations to include motels and restaurants that had substantial effects on interstate commerce.
The Heart of Atlanta Motel was situated next to a Georgia interstate and served mostly out-of-state guests. The motel sued the government, seeking a declaratory judgment that Congress did not have authority under the Commerce Clause to pass the Civil Rights Act. The motel also alleged due-process violations over the deprivation of its right to choose its guests.
In Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), the United States Supreme Court was faced with the question of whether Congress could constitutionally bar racial discrimination in places of public accommodation.
The Court held that Congress’s commerce power extended to the regulation of local incidents of commerce that have a substantial relationship to interstate commerce.
The Civil Rights Act’s legislative history made clear that Congress had concluded that racial discrimination in places of public accommodation discouraged black people from traveling and participating in interstate commerce. Thus, Congress had the constitutional authority to bar such discrimination.
Though there was some debate in the concurrences over whether Congress’s authority to pass the Civil Rights Act was derived from the Commerce Clause or the Fourteenth Amendment, the decision clearly affirmed Congress’s authority to prohibit racial discrimination by private businesses operating in interstate commerce. For that reason, Heart of Atlanta Motel remains a landmark civil-rights case.
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