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Concept
Heart of Atlanta Motel, Inc. v. United States
Summary
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.
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.
The Heart of Atlanta Motel was a large, 216-room motel that opened on September 5, 1956 in Atlanta, Georgia. 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.
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