- [Narrator] In 1964, the Heart of Atlanta Motel
found itself at the heart
of a landmark civil rights dispute.
In Heart of Atlanta Motel versus United States,
the United States Supreme Court established
the foundation for the use of Congress's
Commerce Clause powers to protect civil rights.
Congress enacted the Civil Rights Act of 1964
to prohibit discrimination on the basis of race
in any place of public accommodation.
A place of public accommodation was defined
to include among other things motels and restaurants
if their operations substantially affect
interstate commerce.
The Heart of Atlanta Motel was located
in its namesake city.
The motel advertised in national media,
it was situated conveniently next to interstate highways
and approximately 75% of its business
came from out of state guests.
The motel also practices a policy
of refusing to rent rooms to African Americans.
The motel brought a lawsuit
against the United States government
seeking a declaratory judgment that Congress
had exceeded its constitutional authority
by enacting the Civil Rights Act.
The motel also alleged that the act violated
its due process rights by depriving it
of the right to select its customers
and operate its business as it wished.
A three judge district court panel
upheld the Civil Rights Act as constitutional
under the Commerce Clause and prohibited the motel
from discriminating against African Americans.
On direct appeal, the issue before the Supreme Court
was whether Congress can prohibit racial discrimination
by places of public accommodation
using its Commerce Clause authority.
In an opinion by Justice Clark,
the court held that Congress can enact laws
that prevent racially discriminatory policies
in hotels serving interstate travelers
because these policies substantially affect
interstate commerce.
The court observed the Congress's power
to regulate interstate commerce includes
the power to regulate local incidents of commerce
that have a substantial relation
to the interstate flow of goods.
As a result the court reasoned that Congress
has the power to remove local obstructions
and restraints to interstate commerce.
The court also reviewed the congressional record
for the Civil Rights Act.
The record established that racial discrimination
has a disruptive effect on interstate travel
by substantially discouraging travel
by African Americans.
With no place to stay while traveling,
African Americans were not able to move freely
from state to state and this created
a drag on interstate commerce.
Therefore, the court held that the Civil Rights Act,
as applied to places of public accommodation
that serve interstate travelers, was a valid exercise
of Congress's Commerce Clause authority.
The court affirmed the district court's order
enjoining the motel from discriminating
on the basis of race.
In a concurring opinion, Justice Black agreed
that Congress had the power to regulate
the motel's activities under the Commerce Clause.
Noting that the motel was a large establishment
that advertised extensively on interstate highways,
Black concluded that the motel's
racial discrimination policies
had a great impact on interstate commerce.
Additionally, Black rejected the motel's argument
that the act violated its due process rights.
For one thing, regulating the use of private property
isn't a constitutional taking under the Fifth Amendment.
Additionally, the Fourteenth Amendment,
which was adopted to prohibit discrimination,
can't be used to strip Congress of its power
to protect African Americans from further discrimination.
Justice Douglas, in another concurring opinion,
argued that the court shouldn't have rested
its decision on the Commerce Clause.
By relying solely on Congress's authority
to regulate interstate commerce
the majority implied that an impact on interstate commerce
is a prerequisite for protection against discrimination.
But for Douglas this prerequisite was unnecessary.
Instead he argued that a stronger
and broader basis for Congress's authority
could be found under Section 5
of the Fourteenth Amendment.
Section 5 grants Congress the power to enforce,
by appropriate legislation,
the right of all persons
to equal protection of the law.
Finally, Justice Goldberg, also concurring,
reasoned that the majority opinion
should rest on both the Fourteenth Amendment
and the Commerce Clause,
rather than on one or the other.
For Goldberg, Congress had clear authority
under both provisions to enact the Civil Rights Act.
Heart of Atlanta Motel versus United States
was a landmark Civil Rights decision that allowed
Congress to use its Commerce Clause powers
to combat racial discrimination.