Heart of Atlanta Motel, Inc. v. United States

Last updated

Heart of Atlanta Motel, Inc. v. United States
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued October 5, 1964
Decided December 14, 1964
Full case nameHeart of Atlanta Motel, Incorporated v. United States, et al.
Citations379 U.S. 241 ( more )
85 S. Ct. 348; 13 L. Ed. 2d 258; 1964 U.S. LEXIS 2187; 1 Empl. Prac. Dec. (CCH) ¶ 9712
Case history
PriorJudgment for defendant, 231 F. Supp. 393 (N.D. Ga. 1964); probable jurisdiction noted, 379 U.S. 803(1964).
SubsequentNone
Holding
Congress did not unconstitutionally exceed its powers under the Commerce Clause by enacting Title II of the 1964 Civil Rights Act, which prohibited racial discrimination in public accommodations. Northern District of Georgia affirmed.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black  · William O. Douglas
Tom C. Clark  · John M. Harlan II
William J. Brennan Jr.  · Potter Stewart
Byron White  · Arthur Goldberg
Case opinions
MajorityClark, joined by Warren, Douglas, Harlan, Brennan, Stewart, White, Goldberg
ConcurrenceBlack
ConcurrenceDouglas
ConcurrenceGoldberg
Laws applied
U.S. Const. art. I
Title II of the Civil Rights Act of 1964

Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), was a landmark decision of the Supreme Court of the United States holding that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, religion, or national origin in public accommodations. [1]

Contents

Background

This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. In the 100 years preceding 1964, African Americans in the United States had been subjected to racial segregation, a system of racial separation which, while in name providing for "separate but equal" treatment of both white and African Americans, in fact provided inferior accommodation, services, and treatment for African Americans.

During the mid-20th century, partly as a result of cases such as Powell v. Alabama , 287 U.S. 45 (1932); Smith v. Allwright , 321 U.S. 649 (1944); Shelley v. Kraemer , 334 U.S. 1 (1948); Sweatt v. Painter , 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents , 339 U.S. 637 (1950); NAACP v. Alabama , 357 U.S. 449 (1958); Boynton v. Virginia , 364 U.S. 454 (1960); and, most notably, Brown v. Board of Education of Topeka , 347 U.S. 483 (1954), public opinion began to turn against segregation. Despite the outcomes of these cases, segregation remained in full effect into the 1960s in parts of the southern United States, where the Heart of Atlanta Motel was located.

Court case

Petitioner's argument

The Heart of Atlanta Motel was a large, 216-room motel that opened on September 5, 1956 in Atlanta, Georgia. [2] In direct violation of the terms of the Civil Rights Act of 1964, which banned racial discrimination in public places, largely based on Congress's control of interstate commerce, the motel refused to rent rooms to African-American patrons. The owner, Moreton Rolleston, filed suit in federal court, arguing that the requirements of the Act exceeded the authority the Commerce Clause granted to Congress over interstate commerce. Rolleston specifically argued against Title II of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, religion, or national origin in places of public accommodation. [3] Hotels and motels are included as types of public accommodation in the Act, and so are restaurants that serve food substantially to those who participate in interstate travel. [4] In further arguing against the validity of the Act's basis on the Commerce Clause, he stated that people themselves are not commerce; rather, people engage in commerce. Therefore, a hotel or motel does not necessarily engage in interstate commerce because the profit comes from persons rather than goods. Rolleston also asserted that racial discrimination by an individual is not prohibited by the Fourteenth Amendment or the Constitution, claiming that discrimination is a private wrong that individuals are allowed to commit. [4]

In addition, Rolleston maintained that it violated his Fifth Amendment rights to choose customers and operate his business as he wished and resulted in unjust deprivation of his property without due process of law and just compensation. Finally, he contended that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to African Americans, thereby violating his Thirteenth Amendment rights. Rolleston noted that in 1944 the Fifth Circuit Court of Appeals for the United States held that even if acts committed in involuntary servitude are compensated, it still violates the Thirteenth Amendment. [4]

Rolleston maintained throughout his argument that the Constitution should be interpreted as it was at the time of its creation and as the Framers originally intended it. He concluded his opening argument by stating that the Supreme Court did not need to exist if the Commerce Clause allowed for Congress to enact any regulations it pleases. [4]

Respondent's argument

In response, Archibald Cox, the Solicitor General for the United States, countered that the restrictions requiring adequate accommodation for African Americans were unquestionably related to interstate travel and that Congress, under the Constitution's Commerce Clause, certainly had the power to address such a matter in law. Cox stated that racial discrimination in inns and restaurants “constitute[s] a source of burden or obstruction to interstate commerce.” [4] He brought up multiple examples in which protests over racial discrimination, some in regards to public accommodations and some with broader scopes, intensely affected the economy of certain areas. One of the prime examples was Birmingham, Alabama in the spring of 1963, during which department and downtown store sales dropped dramatically in the area and the amount of business failure rivaled the rates of the Great Depression. [4] Cox also mentioned that areas that do not practice equal opportunity are often overlooked by companies that seek commercial and industrial expansion due to the possibility of demonstrations. He used Little Rock, Arkansas to exemplify this point, as business expansion fell by over 50 million dollars in the two years it experienced high racial tensions. [4]

Cox also highlighted how discrimination by hotels and motels hinders interstate travel by limiting the availability of accommodations for travelers. He described the impediment discrimination imposes with a hypothetical road trip: [4]

On a motor trip between Washington D.C. and Miami, Florida, the average distance that was found between accommodations of reasonable quality open to Negroes was 141 miles. And when we think of the frequency by such we go by other hotels and motels open to everyone, the significance of a three or four-hour drive between the hope of accommodation is very significant indeed. — Archibald Cox

He further argued that the Fifth Amendment does not forbid reasonable regulation of interstate commerce and that such incidental damage did not constitute the "taking" of property without just compensation or due process of law. He emphasized that the courts have consistently sustained cases that strengthen anti-discrimination measures. [4] Lastly, he asserted that the Thirteenth Amendment applies primarily to slavery and the removal of widespread disabilities associated with it and so it undoubtedly would not place issues of racial discrimination in public accommodations beyond the reach of federal and state law: [4]

But surely it would turn the world quite upside down for anyone to seriously suggest that the Thirteenth Amendment was intended to prohibit either Congress or the state governments from guaranteeing Negroes equality of treatment in places of public accommodation. — Archibald Cox

Ruling

The United States District Court for the Northern District of Georgia ruled in favor of the United States and issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination when providing services or goods to guests or the general public on its premises. [5] The case was combined with the case of the future Governor of Georgia Lester Maddox, regarding his Pickrick restaurant and his refusal to serve African Americans. [6]

The opinion of the court, announced on December 14, 1964, was delivered by Justice Tom C. Clark, with concurring opinions by Justice Arthur Goldberg, Justice Hugo Black, and Justice William O. Douglas.

The U.S. Supreme Court held that Congress acted well within its authority under the Commerce Clause in passing the Civil Rights Act of 1964, thereby upholding the act's Title II in question. While it might have been possible for Congress to pursue other methods for abolishing racial discrimination, the way in which Congress did so, according to the Court, was perfectly valid. It found no merit in the arguments pursuant to the Thirteenth Amendment, finding it difficult to conceive that such an amendment might be applicable in restraining civil rights legislation. Having observed that 75% of the Heart of Atlanta Motel's clientele came from out-of-state and that it was strategically located near Interstates 75 and 85 as well as two major Georgia highways, the Court found that the business clearly affected interstate commerce. Accordingly, it upheld the permanent injunction issued by the district court and required the Heart of Atlanta Motel to receive business from the clientele of all ethnicities.

Case legacy

Heart of Atlanta Motel, Inc. v. United States has been cited in at least 690 other case decisions since its ruling, including multiple other Supreme Court cases. [7] A notable example includes the 1997 case Camps Newfound/Owatonna, Inc. v. Town of Harrison, in which a summer camp in Maine that mainly serviced out-of-state residents fought against a state tax exemption statute that favored organizations that serviced state residents. [8] The courts compared out-of-state campers staying at a summer camp to out-of-state residents occupying a hotel, deeming the camp a participant in interstate commerce. [9] Another example is the 1966 case United States v. Guest , in which the courts ruled, due to the conspiratorial murder of Lt. Col. Lemuel Penn while he was traveling home, that forcefully depriving someone's right to travel is unconstitutional. [10]

See also

Related Research Articles

A Congressional power of enforcement is included in a number of amendments to the United States Constitution. The language "The Congress shall have power to enforce this article by appropriate legislation" is used, with slight variations, in Amendments XIII, XIV, XV, XIX, XXIII, XXIV, and XXVI.

The Civil Rights Cases, 109 U.S. 3 (1883), were a group of five landmark cases in which the Supreme Court of the United States held that the Thirteenth and Fourteenth Amendments did not empower Congress to outlaw racial discrimination by private individuals. The holding that the Thirteenth Amendment did not empower the federal government to punish racist acts done by private citizens would be overturned by the Supreme Court in the 1968 case Jones v. Alfred H. Mayer Co. The Fourteenth Amendment not applying to private entities, however, is still valid precedent to this day. Although the Fourteenth Amendment-related decision has never been overturned, in the 1964 case of Heart of Atlanta Motel, Inc. v. United States, the Supreme Court held that Congress could prohibit racial discrimination by private actors under the Commerce Clause, though that and other loose interpretations of the Clause to expand federal power have been subject to criticism.

<span class="mw-page-title-main">Civil Rights Act of 1964</span> Landmark U.S. civil rights and labor law

The Civil Rights Act of 1964 is a landmark civil rights and labor law in the United States that outlaws discrimination based on race, color, religion, sex, and national origin. It prohibits unequal application of voter registration requirements, racial segregation in schools and public accommodations, and employment discrimination. The act "remains one of the most significant legislative achievements in American history".

Separate but equal was a legal doctrine in United States constitutional law, according to which racial segregation did not necessarily violate the Fourteenth Amendment to the United States Constitution, which nominally guaranteed "equal protection" under the law to all people. Under the doctrine, as long as the facilities provided to each race were equal, state and local governments could require that services, facilities, public accommodations, housing, medical care, education, employment, and transportation be segregated by race, which was already the case throughout the states of the former Confederacy. The phrase was derived from a Louisiana law of 1890, although the law actually used the phrase "equal but separate".

The Commerce Clause describes an enumerated power listed in the United States Constitution. The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes". Courts and commentators have tended to discuss each of these three areas of commerce as a separate power granted to Congress. It is common to see the individual components of the Commerce Clause referred to under specific terms: the Foreign Commerce Clause, the Interstate Commerce Clause, and the Indian Commerce Clause.

United States v. Morrison, 529 U.S. 598 (2000), is a U.S. Supreme Court decision that held that parts of the Violence Against Women Act of 1994 were unconstitutional because they exceeded the powers granted to the US Congress under the Commerce Clause and the Fourteenth Amendment's Equal Protection Clause. Along with United States v. Lopez (1995), it was part of a series of Rehnquist Court cases that limited Congress's powers under the Commerce Clause.

<span class="mw-page-title-main">Civil Rights Act of 1875</span> United States federal law

The Civil Rights Act of 1875, sometimes called the Enforcement Act or the Force Act, was a United States federal law enacted during the Reconstruction era in response to civil rights violations against African Americans. The bill was passed by the 43rd United States Congress and signed into law by United States President Ulysses S. Grant on March 1, 1875. The act was designed to "protect all citizens in their civil and legal rights", providing for equal treatment in public accommodations and public transportation and prohibiting exclusion from jury service. It was originally drafted by Senator Charles Sumner in 1870, but was not passed until shortly after Sumner's death in 1875. The law was not effectively enforced, partly because President Grant had favored different measures to help him suppress election-related violence against blacks and Republicans in the Southern United States.

Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages.

National League of Cities v. Usery, 426 U.S. 833 (1976), was a case in which the Supreme Court of the United States held that the Fair Labor Standards Act could not constitutionally be applied to state governments. The decision was overruled by the U.S. Supreme Court in Garcia v. San Antonio Metropolitan Transit Authority.

Katzenbach v. McClung, 379 U.S. 294 (1964), was a landmark decision of the U.S. Supreme Court which unanimously held that Congress acted within its power under the Commerce Clause of the United States Constitution in forbidding racial discrimination in restaurants as this was a burden to interstate commerce.

Bell v. Maryland, 378 U.S. 226 (1964), provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the United States Constitution. However, due to a supervening change in the state law, the Court vacated the judgment of the Maryland Court of Appeals and remanded the case to allow that court to determine whether the convictions for criminal trespass of twelve African American students should be dismissed.

<i>Keys v. Carolina Coach Co.</i> Landmark 1955 US civil rights case

Sarah Keys v. Carolina Coach Company, 64 MCC 769 (1955) is a landmark civil rights case in the United States in which the Interstate Commerce Commission, in response to a bus segregation complaint filed in 1953 by a Women's Army Corps (WAC) private named Sarah Louise Keys, broke with its historic adherence to the Plessy v. Ferguson separate but equal doctrine and interpreted the non-discrimination language of the Interstate Commerce Act as banning the segregation of black passengers in buses traveling across state lines.

The Jim Crow laws were state and local laws introduced in the Southern United States in the late 19th and early 20th centuries that enforced racial segregation, "Jim Crow" being a pejorative term for an African American. Such laws remained in force until 1965. Formal and informal segregation policies were present in other areas of the United States as well, even as several states outside the South had banned discrimination in public accommodations and voting. Southern laws were enacted by white-dominated state legislatures to disenfranchise and remove political and economic gains made by African Americans during the Reconstruction era. Such continuing racial segregation was also supported by the successful Lily-White Movement.

In United States law, public accommodations are generally defined as facilities, whether publicly or privately owned, that are used by the public at large. Examples include retail stores, rental establishments, and service establishments as well as educational institutions, recreational facilities, and service centers.

Arizona Public Service Co. v. Snead, 441 U.S. 141 (1979), was a United States Supreme Court case in which the Court held that a New Mexico tax on the generation of electricity was invalid under the Supremacy Clause of the United States Constitution. Snead was the director of the New Mexico Taxation and Revenue Department.

Garner v. Louisiana, 368 U.S. 157 (1961), was a landmark case argued by Thurgood Marshall before the US Supreme Court. On December 11, 1961, the court unanimously ruled that Louisiana could not convict peaceful sit-in protesters who refused to leave dining establishments under the state's "disturbing the peace" laws.

Hall v. Decuir, 95 U.S. 485 (1878), was a decision of the Supreme Court of the United States. In Hall, Josephine Decuir, a wealthy woman designated a Creole, sued for racial discrimination she experienced on a steamboat. She was traveling from New Orleans to Pointe Coupee Parish, where she owned a sugar plantation.

References

  1. ↑ Heart of Atlanta Motel, Inc. v. United States., 379 U.S. 241 (1964).
  2. ↑ "Heart of Atlanta Motel". todayingeorgiahistory.org/. Retrieved April 14, 2020.[ permanent dead link ]
  3. ↑ "Department of Justice". www.justice.gov. August 6, 2015. Archived from the original on April 13, 2016. Retrieved March 17, 2020.
  4. 1 2 3 4 5 6 7 8 9 10 "Heart of Atlanta Motel, Inc. v. United States". Oyez. Retrieved March 16, 2020.
  5. ↑ Heart of Atlanta Motel, Inc. v. United States, 231F. Supp.393 ( N.D. Ga. 1964).
  6. ↑ Heart of Atlanta/Pickrick trial. Civil Rights Digital Library. Retrieved 2014-05-23
  7. ↑ "Document: Heart of Atlanta Motel v. United States, 379 U.S. 241". Nexis Uni. December 14, 1964. Retrieved April 16, 2020.
  8. ↑ "Camps Newfound/Owatonna, Inc. v. Town of Harrison". Oyez. Retrieved April 16, 2020.
  9. ↑ "Document: Camps Newfound/Owatonna v. Town of Harrison, 520 U.S. 564". Nexis Uni. May 19, 1997. Retrieved April 16, 2020.
  10. ↑ "United States v. Guest". Oyez. Retrieved April 16, 2020.
This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.