一、 Heart of Atlanta Motel, Inc. v. United States
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.
For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for “separate but equal” treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans. This case hinged on whether the federal government has the power to make private discrimination a crime.
Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers?
The Supreme Court ruled that Congress had the power under the Commerce Clause to enact the prohibitions on discrimination contained in the public accommodations section of the Civil Rights Act of 1964. Justice Thomas Clark wrote the opinion for a unanimous Court. He reviewed testimony presented at congressional hearings showing that Americans had become increasingly mobile, but that African Americans were discriminated against by hotels and motels, and often had to travel longer distances to get lodging or had to call on friends to put them up overnight.
Justice Clark noted that under the Interstate Commerce Act, “the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the States of origin and destination, which might have a substantial and harmful effect upon that 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.”
Justice Clark also found that the Act did not deprive the motel owner of liberty or property under the Fifth Amendment. Because Congress has the right to prohibit discrimination in accommodations under the Interstate Commerce Act, the motel “has no 'right' to select its guests as it sees fit, free from governmental regulation.”
During this era of Commerce Clause jurisprudence, actions by the federal government under this power were upheld if they regulated an activity that affected more than one state and had a substantial overall effect on national commerce. Although this case was important and influential, coming early in the Civil War era, the arguments that Rolleston advanced were so dubious at face value that the outcome was never seriously in doubt.