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Heart of Atlanta Motel v United States

Supreme Court Decision: Civil Rights Act Protected by Interstate Commerce Clause


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Background: The 1964 HOA Motel v U.S. Supreme Court decision extended the Civil Rights Act by way of the Interstate Commerce Clause. The owner of the hotel violated the Civil Rights Act by refusing to serve African American customers. He claimed that the Act was unconstitutional, that he his right to serve who he chose was guaranteed by the 5th Amendment, and that to force him to serve certain customers amounted to "involuntary servitude" prohibited by the 13th Amendment.

Outcome: The Court denied the hotel owner's contentions. The Court relied on Congress's power to regulate interstate commerce to justify the decision, rather than explicitly ruling on the discriminatory practice. The Court described the issue it faced as follows: "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." The Court then examined the facts of the case to make a judgment.

The Court found that because the motel likely served people engaging in interstate travel, interstate commerce was affected. They concluded "One need only examine the evidence which we have discussed above to see that Congress may -- as it has -- prohibit racial discrimination by motels serving travelers, however 'local' their operations may appear." While the Court, likely for practical purposes, avoided the moral question at hand, they paid it service, stating that the fact "that Congress was legislating against moral wrongs in many of these areas rendered its enactments no less valid."

The Court was not persuaded by the plaintiff's 5th Amendment claims as "The commerce power invoked here by the Congress is a specific and plenary one authorized by the Constitution itself." The Court stated that the appellant would not likely be subject to economic loss, but even had he, the law would not have been unjust.

Text of Majority Opinion.

By Nick Karasimas

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