Heart of Atlanta Motel v. United States

What happens when a business doesn't want to follow a national civil rights law? This article explores a landmark Supreme Court case that upheld the rights granted by the Civil Rights Act of 1964 and reinforced Congress’ efforts to guarantee that no citizens would be discriminated against on the basis of race, ethnicity, nationality, or skin color. We will examine the background of the case, the Court’s ruling, and the impact that ruling had on the United States.

Heart of Atlanta Motel v. United States Case Summary

Case Parties

• The Appellant, Moreton Rolleston, Jr., was an Atlanta lawyer and the owner of the Heart of Atlanta Motel. He brought the case before the United States Supreme Court.

• The Appellee, the United States, was represented by Attorney General Robert F. Kennedy.

Photograph of Attorney General Robert F. Kennedy, Warren K. Leffler, Wikimedia Commons.

Background

The Heart of Atlanta Motel was located near interstate highways 75 and 85 as well as state highways 23 and 41. The motel utilized different forms of national media to advertise its business, including 50 billboards and signs in the state of Georgia, and nationally distributed magazines. Moreton Rolleston, the owner of the motel, refused to rent rooms to people of color prior to the passage of the Civil Rights Act of 1964 and stated he would continue to do so even after the Act was passed. After the Civil Rights Act was passed, Rolleston sued the United States government alleging violations of his rights under the 5th and 13th Amendments. The case was brought before the District Court of Northern Georgia on July 22, 1964.

Appellant’s arguments

The Heart of Atlanta Motel argued that Congress had gone beyond its powers to regulate commerce when it passed the Civil Rights Act of 1964. The owner claimed that his Fifth Amendment rights were violated because he was being told how to run his business and he couldn’t choose his customers. He also claimed that having to serve people of color would subject him to involuntary servitude against his rights guaranteed by the Thirteenth Amendment.

The motel asked the Court for an injunction prohibiting the enforcement of the Act. They also also requested that the appellees pay damages for any resulting injury that would happen if the Act was to be enforced. However, the appellants submitted no evidence at trial and instead chose to rely on the pleadings, admissions, and a stipulation of facts.

Appellee’s Counterarguments

Attorney General Robert F. Kennedy argued that the motel owner's Fifth Amendment right was not violated because thecommerce clausegave Congress the power of reasonable regulation over interstate travel and commerce. The motel owner's Thirteenth Amendment right was also not violated because having to serve people of color at the motel cannot be compared to slavery or involuntary servitude.

The government countered the motel's arguments by stating that interstate travel and commerce were affected by the lack of accommodations available to people of color and that Congress was well within its power to remove any obstructions. Attorney General Robert F. Kennedy argued that the motel owner’s Fifth Amendment right was not violated because the amendment doesn’t stop Congress from reasonable regulation and, under the amendment, the results of such regulations can’t be considered taking private property for public use. As for the motel's claim that his Thirteenth Amendment right had been violated by having to serve people of color at the motel, the government argued the owner’s idea that the abolition of slavery, involuntary servitude, and the institutions that disadvantaged those subjected to it could be applied to allow discrimination in public accommodations was not how the law was to be applied.

The government requested that the Act be enforced and requested a trial before a three-judge district court. During the trial, the government produced evidence of the motel’s refusal to serve people of color after the Civil Rights Act of 1964 was passed.

Heart of Atlanta Motel V. United States Court Ruling

The District Court of Georgia confirmed the validity of the Civil Rights Act of 1964 as applied to this case. It issued an injunction in favor of the appellees that prohibited the appellant from refusing to serve people of color and continuing to violate the Act. The owner of the motel filed an appeal which was brought before the United States Supreme Court on October 5, 1964.

The Warren Court unanimously ruled in favor of the government (9-0). The majority opinion was written by Justice Clark. Concurring opinions were written by Justices Black, Goldberg, and Douglas.

The Warren Court issued a unanimous (9-0) decision in favor of the government. The decision was written by Justice Tom C. Clark. Justices Hugo Black, Arthur Goldberg, and William O. Douglas wrote a separate concurring decisions.

The Supreme Court took into account the historyof the country’s Civil Rights Acts and Title II of the Civil Rights Act of 1964 and applied them to the case to make their decision.

The 1964 Civil Rights Act

Title II of the Act protects the right to enjoy public spaces and services. It also guarantees that an individual cannot be discriminated against based on race, religion, ethnicity, or skin color. In this case, Title II applied to places like motels, hotels, and inns that provided lodging or meals to interstate travelers. The Act overrides state laws legalizing discrimination and/or segregation and prohibits anyone from using coercion, threats, or intimidation to prevent someone from exercising the rights guaranteed by the Act.

United States Supreme Court Decision

The Supreme Court upheld the decision of the District Court in a unanimous opinion written by Justice Tom C. Clark. The Court found that Congress' power to regulate commerce under theCommerce Clauseof the U.S. Constitution was enough to make its ruling. The Commerce Clause (Article I, Section 8) granted Congress the power to regulate commerce among several States. In promoting interstate commerce, Congress has the power to regulate incidents that occur in the State of origin and the destination if it negatively affects commerce.

Photograph of Supreme Court 1962-1965, Warren K. Leffler, Wikimedia Commons.

As for the appellant’s other claims, the Court found there is no evidence to support that he would suffer economic loss in the enforcement of the Act or that the appellant’s property was being taken without proper compensation. The Court also found nothing to support the appellant’s claim of being forced into involuntary servitude.

Impact of the Heart of Atlanta Motel v. United States Outcome

The Heart of Atlanta Motel v. United States was the first test of the validity of the Civil Rights Act of 1964 and solidified the Court’s efforts to guarantee equality for all U.S. citizens. It played a major role in dismantling the Jim Crow systems that were still in place in the South. The decision also demonstrated Congress’ power to pass legislation under theCommerce Clause.