Landmark U.S. Supreme Court CaseHeart of Atlanta Motel v. United States

The Heart of Atlanta Motel, which was located in the state of Georgia, had 216 rooms available to guests. The motel was readily accessible to motorists using U.S. interstate highways 75 and 85 and Georgia state highways 23 and 41. The motel solicited patronage from outside the state of Georgia through various national advertising media, including magazines of national circulation. Approximately 75 percent of the motel’s registered guests were from out of state. The Heart of Atlanta Motel refused to rent rooms to blacks. Congress enacted the Civil Rights Act of 1964, which made it illegal for motels, hotels, and other public accommodations to discriminate against guests based on their race. After the act was passed, the Heart of Atlanta Motel continued to refuse to rent rooms to blacks. The owner-operator of the motel brought a declaratory relief action in U.S. district court, Heart of Atlanta Motel v. United States, to have the Civil Rights Act of 1964 declared unconstitutional. The plaintiff argued that Congress, in passing the act, had exceeded its powers to regulate interstate commerce under the Commerce Clause of the U.S. Constitution.

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The U.S. Supreme Court held that the provisions of the Civil Rights Act of 1964 that prohibited discrimination in accommodations properly regulated interstate commerce. In reaching its decision, the U.S. Supreme Court stated: The power of Congress over interstate commerce is not confined to the regulation of commerce among the states. 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. One need only examine the evidence which we have discussed above to see that Congress may—as it has—prohibit racial discrimination by motels serving travelers, however “local” their operations may appear. Questions: Why was this case so important? Why did the U.S. Supreme Court develop the “effects on interstate commerce” test? Is most commerce considered “interstate commerce”?