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Happy Birthday to Heart of Atlanta Motel!

Thanks to Today in Legal History for providing such good material. On this day 43 years ago, the Supreme Court upheld the constitutionality of the 1964 Civil Rights Act in the case Heart of Atlanta Motel v. United States.

The case was brought to the Supreme Court by attorney and notorious segregationist Moreton Rolleston who refused to let African Americans stay at his motel. The property bordered "on an interstate highway...advertises in national magazines and gets 75% of its guests from outside Georgia," according to a Time magazine article at the time.

Rolleston actually represented himself in front of the Supreme Court. Time notes: "Ignoring that evidence, the motel's Owner-Lawyer Moreton Rolleston Jr. proceeded to lecture the Justices: 'The argument that this law was passed to relieve a burden on interstate commerce is so much hogwash. It was intended to regulate the acts of individuals.' If the commerce clause can be stretched that far, declared Rolleston, 'Congress can regulate every facet of life.'"

Rolleston also argued that by requiring him to "rent available rooms to Negroes against its will, Congress is subjecting it to involuntary servitude in contravention of the Thirteenth Amendment." Hahahaha. I can't even write that with a straight face.

Needless to say, a unanimous Supreme Court rejected all of Rolleston's arguments in issuing the most important Commerce Clause decision since the New Deal. Rolleston eventually sold the property, rather than obey the Court's decree. That property is now home to the Atlanta Hilton. Justice Tom Clark (who wrote an amicus brief in Shelley v. Kraemeras President Truman's Solicitor General), concluded his opinion for the Court by saying:

We therefore conclude that the action of the Congress in the adoption of the Act as applied here to a motel which concededly serves interstate travelers is within the power granted it by the Commerce Clause of the Constitution, as interpreted by this Court for 140 years. It may be argued that Congress could have pursued other methods to eliminate the obstructions it found in interstate commerce caused by racial discrimination. But this is a matter of policy that rests entirely with the Congress, not with the courts. How obstructions in commerce may be removed -- what means are to be employed -- is within the sound and exclusive discretion of the Congress. It is subject only to one caveat -- that the means chosen by it must be reasonably adapted to the end permitted by the Constitution. We cannot say that its choice here was not so adapted. The Constitution requires no more.

Full post as published by Supreme Dicta on December 14, 2007 (boomark / email).