Heart of Atlanta Motel, Inc. v. United States

Facts

Heart of Atlanta Motel, Inc. owned and ran the Heart of Atlanta Motel in Atlanta, which had 216 rooms available to transient guests. It stood on Courtland Street, two blocks from downtown Peachtree Street, and was readily accessible to interstate highways 75 and 85 and state highways 23 and 41. The motel sought customers from outside Georgia through national advertising, including magazines of national circulation, and kept over 50 billboards and highway signs in the State. It also took convention trade from outside Georgia, and approximately 75% of its registered guests came from out of State. Before the Civil Rights Act of 1964 passed, the motel refused to rent rooms to Black people. It said it meant to keep doing so. Title II of the Act gives all persons the full and equal enjoyment of places of public accommodation without discrimination on grounds of race, color, religion or national origin. It covers any motel providing lodging to transient guests, except a building with not more than five rooms for rent that the proprietor lives in, and treats such a motel as affecting commerce per se. The case came up on admissions and stipulated facts. The motel admitted that it fell within the Act and that it refused lodging to transient Black guests and meant to continue unless stopped.

Issues

1. Did Congress have power under the Commerce Clause to forbid racial discrimination by a motel that serves interstate travelers, even though the motel's operations may be local?
2. Does applying Title II to the motel violate the Fifth Amendment's Due Process and Takings Clauses, or the Thirteenth Amendment's ban on involuntary servitude?

Holding

Title II of the Civil Rights Act of 1964, as applied to a motel that concededly serves interstate travelers, is within Congress's power under the Commerce Clause. It does not violate the Fifth or Thirteenth Amendment. The Court rested only on the commerce power.