Heart of Atlanta V. United States

Heart of Atlanta v. United States

Heart of Atlanta v. United States (1964) - Any business that was participating in interstate commerce would be required to follow all rules of the federal civil rights legislation. In this case, a motel that wanted to continue segregation was denied because they did business with people from other 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. During the mid-twentieth 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 probably the most famous, Brown v. Board of Education of Topeka, 347 U.S. 483 (1954), the tide against segregation and white supremacy began to turn. However, black Americans' fight for equal civil rights was far from over. In particular, the southern United States, where the Heart of Atlanta Motel was located, remained segregated even into the late 1960s.Passed on July 2, 1964, the Civil Rights Act of 1964 banned racial discrimination in public places, particularly in public accommodations, largely based on Congress' control of interstate commerce.The Heart of Atlanta motel was a large, 216-room motel in Atlanta, Georgia, which refused to rent rooms to black patrons, in direct violation of the terms of the act. The owner of the motel filed suit in federal court, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. In addition, the owner argued that the act 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, the owner argued that Congress had placed him in a position of involuntary servitude by forcing him to rent available rooms to blacks, thereby violating his Thirteenth Amendment rights.

In response, the United States countered that the restrictions in adequate accommodation for black Americans severely interfered with interstate travel, and that Congress, under the United States Constitution's Commerce clause, was certainly within its power to address such matters. Moreover, they argued, the Fifth Amendment does not forbid reasonable regulation of interstate commerce and such incidental damage did not constitute the "taking"