Heart of Atlanta Motel V. United States - The Case

The Case

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, Moreton Rolleston, 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" of property without just compensation or due process of law. Third, they argued that the Thirteenth Amendment applied primarily to slavery and the removal of widespread disabilities associated with it; in such kind, the Amendment certainly would not place issues of racial discrimination in public accommodations beyond the reach of Federal and state law.

The District court ruled in favor of the United States and issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from using racial discrimination in terms of the goods or services that it offered to guests or the general public upon its premises. The owner of the motel was Attorney Moreton Rolleston. This case was combined with the case of the future Governor of Georgia Lester Maddox concerning his Pickrick restaurant and his case to refuse to serve blacks.