Heart of Atlanta Motel
The Heart of Atlanta Motel
Located in downtown Atlanta, Georgia.
Had 216 rooms.
75% of its guest was from out of state (interstate commerce).
Civil Rights Act of 1964
Title II of the 1964 Civil Rights Act that "All persons shall be
entitled to the full and equal enjoyment of the goods, services,
facilities, privileges, advantages, and accommodations of any
place of public
accommodation, as defined in this section,
discrimination or segregation on the ground of race, color,
religion, or national origin."
Public Accommodations (def)
Place of public accommodation as those whose operations affect
The Heart of Atlanta Motel sought a declaratory judgment that
Title II was unconstitutional.
Power to regulate interstate commerce
The Court upheld the statute as a valid exercise of power to
regulate interstate commerce.
Reliance on the burdens of discrimination in Congressional
People have become increasingly mobile with millions of people
of all races traveling from State to State;
[African Americans] in particular have been the subject of
discrimination in transient accommodations, having to travel
great distances [obtain security].
[African Americans] often [were] unable to obtain
accommodations and [had to stay with] friends overnight,
[African Americans] in a special guidebook that told there were
to obtain lodging.
Qualitative and Quantitative Effects
This testimony indicated a qualitative as well as quantitative
effect on interstate travel by Negroes.
The former [Qualitative] was the obvious impairment of the
[African Americans] traveler's pleasure and convenience that
resulted when he continually
was uncertain of finding lodging.
As for the latter [Quantitative Effect], there was evidence that
this uncertainty stemming
from racial discrimination had the
effect of discouraging travel
on the part of a substantial portion
of the [African Americans] community.
In relation to Interstate commerce
[There] is overwhelming evidence of the disruptive effect that
racial discrimination has had on commercial intercourse.
Discrimination Burden Empowers Congress
It was this burden which empowered Congress to enact appropriate
Congress was not restricted by the fact that the particular
obstruction to interstate commerce with which it was dealing was
also deemed a moral and social wrong.
Motel was of a purely local character
It did not matter that the motel was of a purely local
character because the
power of Congress to promote interstate commerce also
included the power to regulate the
local incidents thereof, including
local activities in both the state of
origin and destination,
MIGHT have a substantial and harmful effect upon that
Obstructions of Commerce
Obstructions of Commerce are within the sound discretions of
chosen by it must be reasonably adapted to the
END permitted by the