1. Heart of Atlanta Motel v. United States, (1964)
2. Facts: The hotel had 216 rooms and was located within ready access to two interstate highways. It advertised in national media, and was a center for conventions of out of state guests. The hotel refused to rent rooms to African Americans.
3. Procedural Posture: The hotel brought a declaratory judgment action attacking the constitutionality of Title II of the Civil Rights Act of 1964, which prohibited discrimination on the basis of race in places of “public accommodation,” and which grounded its authority primarily in the commerce power. The District Court upheld the Act, and the Hotel appealed.
4. Issue: Whether application of Title II of the Civil Rights Act of 1964 to a motel which serves interstate customers is within the constitutional power of Congress under the Commerce Clause.
5. Holding: Yes. “The determinative test of the exercise of power by the Congress under the Commerce Clause is simply whether the activity sought to be regulated is ‘commerce which concerns more States than one’ and has a real and substantial relation to the national interest.”
6. ∏ Argument: Congress did not have the power to legislate against moral wrongs under the guise of the Commerce Power. Even if they did, the operation of a motel is purely local in character, and thus does not affect interstate commerce.
7. ∆ Argument: Discrimination by hotels has a significant effect on interstate commerce by deterring African Americans to travel.
8. Majority Reasoning: There is ample evidence in the Congressional record that discrimination by places of public accommodation impair African-Americans’ ability to travel, thus affecting interstate commerce. Thus, the Act passed the test of “commerce which concerns more States than one,” and discrimination had a substantial relation to the national interest. The court then listed several examples of factual scenarios where the Congress had legitimately exercised the commerce power to police activities which were both immoral and had an adverse affect on interstate commerce. “That Congress was legislating against moral wrongs...rendered its enactments no less valid.” Furthermore, “if it is interstate commerce that feels the pinch, it does not matter how local the operation that applies the squeeze.” Thus, the commerce power encompasses the regulation of local activities that have an affect on interstate commerce.
