Heart of Atlanta Motel v. United States Case Brief

Facts of the case

Title II of the Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce. The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans. The government sought to enjoin the motel from discriminating on the basis of race under Title II.

Why is the case important?

Prior to passage of the Civil Rights Act of 1964 (the Act), the Appellant, Heart Atlanta Motel, Inc. (Appellant) operated a motel which refused accommodations to blacks. Appellant intended to continue this behavior to challenge Congress’ authority to pass the Act.


May Congress prohibit racial discrimination in hotel lodging under the Commerce Clause?


Yes. Appeals court ruling affirmed.
Congress heard testimony from many sources describing the hardships blacks face in securing transient accommodations throughout the United States. With an increasingly mobile populace, this brought increasing difficulties to many United States citizens. It does not matter that Congress was addressing a moral issue (see the dissent in Hammer v. Dagenhart, 247 U.S. 251 (1918) and the Supreme Court of the United States’ (Supreme Court) opinion in Darby, 312 U.S. 100 (1941). What the Supreme Court is examining is Congress’ power to enact the legislation, not the impetus behind the Act.


The Supreme Court of the United States held that the Civil Rights Act was a proper exercise of the commerce power and that Congress was within its power to prohibit racial discrimination by motels serving travelers, however local their operations appeared. Affirming the judgment, the Court held that the power of Congress over interstate commerce extended to those intrastate activities that so affected interstate commerce or the exercise of Congressional power over it to make regulation of them an appropriate means to exercise its power over interstate commerce. Further, the power of Congress to promote interstate commerce also included the power to regulate the local incidents thereof, including local activities in both the state of origin and destination, which might have a substantial and harmful effect upon that commerce.

  • Advocates: –
  • Appellant: Heart of Atlanta Motel, Inc.
  • Appellee: United States
  • DECIDED BY:Warren Court
  • Location: Heart of Atlanta Motel
Citation: 379 US 241 (1964)
Argued: Oct 5, 1964
Decided: Dec 14, 1964
Heart of Atlanta Motel v. United States Case Brief