Docket 515
Heart of Atlanta Motel, Inc. v. United States
DecidedJan 25, 1965
9-0unanimous decision
Source: CourtListener.
Supreme Court upholds Civil Rights Act's ban on race discrimination by hotels and motels serving travelers
Impact9/10
What it does
The ruling upholds Title II of the Civil Rights Act of 1964 as applied to a motel that serves interstate travelers, finding Congress had the power under the Commerce Clause to ban racial discrimination in places of public accommodation that affect interstate commerce. It rejects claims that the law violates the Fifth Amendment's due process protections or the Thirteenth Amendment's ban on involuntary servitude.
Who benefits
Black travelers and other racial minorities seeking lodging, food, and other public accommodations while traveling across state lines.
Who is affected
Owners of motels, hotels, and similar businesses that serve interstate travelers, who must now serve customers regardless of race even if they would prefer not to.
Practical impact
Hotels, motels, and other public accommodations serving interstate travelers were required to stop refusing service based on race, ending a common practice that had made travel difficult and sometimes impossible for Black Americans in many parts of the country. The ruling confirmed that similar restaurants and public accommodations covered by Title II could also be required to desegregate, since the reasoning applied broadly to businesses with a substantial connection to interstate commerce.
Majority reasoning
The majority, led by Justice Clark, held that the Commerce Clause gives Congress broad power to regulate activities that substantially affect interstate commerce, even when the regulated conduct itself happens locally. The Court found extensive evidence before Congress that racial discrimination in lodging discouraged travel by Black Americans and disrupted the national flow of commerce, which gave Congress a rational basis to act. The Court distinguished this case from the 1883 Civil Rights Cases, which struck down an earlier civil rights law, noting that the earlier law was not grounded in the Commerce Clause and that conditions of interstate travel had changed dramatically since then. The Court also rejected the Fifth Amendment due process and Thirteenth Amendment involuntary servitude arguments, noting that regulating property use for a legitimate public purpose does not violate due process and that requiring service to all customers is nothing like slavery, especially since many states already had similar public accommodation laws on their books.
Constitutional question
Did Congress exceed its power under the Commerce Clause by requiring a motel that serves interstate travelers to stop refusing rooms to Black customers, and does that requirement violate the Fifth Amendment or Thirteenth Amendment?
Precedent changed
The Court found the 1883 Civil Rights Cases, which struck down an earlier public accommodations law, to be inapplicable rather than overruled, since that case did not address whether such a law could be justified under the Commerce Clause.