Heart of Atlanta Motel v. United States

Heart of Atlanta Motel v. United States, 379 U.S. 241 (1964), is a landmark decision of the United States Supreme Court.

Title II of the Civil Rights Act of 1964 prohibited racial discrimination in public accommodations. The Heart of Atlanta Motel, which refused to serve Black customers, challenged the law as exceeding Congress’s Commerce Clause power. The motel argued that discrimination was a moral and social issue, not an economic one subject to federal regulation.

Significance

Justice Clark’s unanimous opinion upheld Title II as a valid exercise of Commerce Clause power. The Court found that racial discrimination in public accommodations had a substantial effect on interstate commerce — it discouraged travel by Black Americans and imposed burdens on businesses serving interstate travelers. The decision was a masterful use of the Commerce Clause to achieve civil rights goals, bypassing the state action limitation that had doomed the Civil Rights Act of 1875. Heart of Atlanta and its companion case, Katzenbach v. McClung (1964), ensured the constitutionality of the landmark Civil Rights Act.

Category

US Federal Case Law