Atlanta Motel v United States

Atlanta Motel v United States, 379 U.S. 241 (1964)

FACTS:
Heart of Atlanta Motel runs a large motel (216 rooms) which restricts its clientele to white people. As a result of extensive out-of-state advertising, 75% of its clientele are transient interstate travelers, and it is located on Courtland St in such a manner as to allow ready access to interstate highways 75 and 85, and state highways 23 and 41.. Appellant sued for declaratory relief claiming Congress did not have the constitutional ability to prohibit racial discrimination in this place of public commerce. The District Court permanently enjoined appellant from racial discrimination.

ISSUE:
Is Title II of the Civil Rights Act of 1964 a valid exercise of Congress’ power under the Commerce Clause? (Yes)
Is the prohibition of racial discrimination in public accommodations a deprivation of property or liberty without due process of law? (No)
Is said prohibition a violation of the 13th Amendment as being “involuntary servitude”? (No)

REASONING:
(Clark)
Having established the Heart of Atlanta Motel fits into one of the four classes of businesses which are covered by Title II (as “any inn, hotel, motel… which provides lodging to transient guests…”), The Court continues to determine whether the Civil Rights Act of 1964 is constitutional as applied to this situation. The court acknowledges that the power to control commerce is sufficient for this issue, and continues to establish that a significant percentage of State to State transit is comprised of a non-white population. Because these interstate travelers require lodging, the lack of lodging would severely hinder interstate commerce. Additionally, interstate traffic is considered interstate commerce without question, and does not need to be commercial in nature.

The aforementioned power to “regulate” consists of any and all action of any nature because the power granted to Congress is plenary and requires only that said actions have a “real and substantial relation to the national interest”. The intent of Title II is to eliminate racial discrimination because overwhelming evidence provides it has a disruptive effect on commercial intercourse. Included in said plenary powers is the ability to promote interstate commerce, and to that end Congress can prohibit racial discrimination in relevant establishments at their discretion.

By citing the provisions of 32 states, the Court summarily dismisses the argument that the prohibition of racial discrimination is a taking of property without just compensation, along with the argument that the requirement for appellant to lodge non-white clientele is involuntary servitude.

CONCURRING:
(Black)
Justice Black concurs, and additionally cites the applicability of Title II to a similar case involving “Ollie’s Barbecue”. This case did not involve interstate travelers, but rather imported a significant portion (46%) of its meats and supplies from out of state. Both cases defeated racial discrimination with an application of Title II of the Civil Rights Act of 1964.

(Douglas)
Justice Douglas concurs, although expresses his reluctance to rely solely on the Commerce Clause, and offers the 14th Amendment as a better alternative.

(Goldberg)
Justice Goldberg concurs, and does not challenge the right application of the Commerce Clause, but would like to reiterate the purpose of the Civil Rights Act of 1964: to vindicate human dignity.

HOLDING:
Congress was within her Constitutional right to enact Title II of the Civil Rights Act of 1964 as a valid exercise of power granted to Congress by the Commerce Clause. By invoking Title II, the requirement for appellant to eliminate racial discrimination is a valid exercise of governmental power and is not a deprivation of property or liberty without due process or just compensation; it also does not constitute involuntary servitude as defined by the 13th Amendment’s intention.