Heart of Atlanta Motel, Inc. v. United States

14 December 1964

On 14 December 1964 the Supreme Court unanimously affirmed the lower-court judgment against the Heart of Atlanta Motel. Justices Black, Douglas and Goldberg wrote separate concurrences; there was no dissent.

Justice Tom C. Clark's opinion held that Title II of the Civil Rights Act of 1964 was a valid exercise of Congress's Commerce Clause power as applied to a motel serving interstate travelers.

The Court found no Fifth Amendment due-process or taking violation, and rejected the motel's argument that accepting Black guests would constitute involuntary servitude under the Thirteenth Amendment.

Three-quarters of the guests came from out of state

The Court relied on stipulated facts. The 216-room motel actively solicited interstate travelers, maintained more than 50 billboards and highway signs in Georgia, and drew approximately three-quarters of its registered guests from outside the state.

Evidence before Congress had described stretches averaging 141 miles between reasonable-quality accommodations open to Black motorists on a Washington-to-Miami route.

What the judgment actually did

It left in force a permanent district-court injunction prohibiting the motel from refusing Black guests or distinguishing among guests because of race or color. The Supreme Court did not issue that injunction; it affirmed the court that had.

The holding upheld Title II as applied to this interstate-oriented motel, resting on the Commerce Clause rather than primarily on the Fourteenth Amendment. The same day, Katzenbach v. McClung upheld Title II as applied to a restaurant whose operations affected interstate commerce.