Heart of Atlanta Motel v. United States

Warren CourtCivil Rights

The Court upheld Title II of the Civil Rights Act of 1964 barring racial discrimination in public accommodations.

Overview

A downtown Atlanta motel refused Black guests and challenged the public accommodations provisions of the 1964 act. The Court held that Congress could regulate racial discrimination by businesses serving interstate travelers under the Commerce Clause, and that the Thirteenth Amendment argument failed because the motel imposed no involuntary servitude. The decision answered objections that the statute exceeded federal power, validated the landmark law, and ended the era when private discrimination in hotels and restaurants could defeat federal policy. It stands as a high-water mark of congressional commerce power deployed against racial discrimination.

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