Federal Ban Of Racial Discrimination In Public Accommodations Upheld

1964

In Heart of Atlanta Motel v. United States, the owners of a large motel in Atlanta, Ga., which restricts its clientele to white people, three-fourths of whom are transient interstate travelers, ask the courts to stop the enforcement of the Civil Rights Act of 1964. The hotel owners says Congress does not have the power to prohibit racial discrimination in places of public accommodation because neither the 13th, 14th, nor the 15th Amendment authorizes Congress to regulate private action. The owners also argue that the commerce clause (the phrase in the Constitution that gives Congress the power to regulate business transactions across state lines) does not include behavior such as this. In an important civil rights case, the Court here upholds the Civil Rights Act by finding that Congress can regulate hotels since interstate travel is “commerce.” At the same time, the Court finds that the race discrimination at issue here does not violate either the Fifth Amendment’s due process clause or the 13th Amendment’s prohibition on “involuntary servitude.”

In a companion case, Katzenbach v. McClung, restaurant owners challenge the power to prohibit discrimination in their establishments. Relying on its decision in Heart of Atlanta Motel, the U.S. Supreme Court upholds the Civil Rights Act finding that restaurants participate in interstate commerce.