Category Archives: 1964 Civil Rights Act

Heart of Atlanta Motel, Inc. v. United States: Title II 1964 Civil Rights Act; Motel Racial Discrimination (12/14/1964)

Heart of Atlanta Motel, Inc. v. United States

Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers?

Argued: 10/05/1964

Decision Date: 12/14/1964

Decision Record: 9-0; no

Justice Majority: Earl Warren, Hugo Black, William Douglas, Tom Clark, John Harlan, William Brennan, Potter Stewart, Byron White, Arthur Goldberg

Justices Dissenting: None

Effect of the Decision

This case ruled that Congress has the right to deprive motels of the right to choose their own customers.

In Favor

In the favoring side of this case, on the side of the Heart of Atlanta Motel, attorney Moreton Rolleston, Jr. argued, “This is an appeal from a final judgment in the United States District Court for the Northern District of Georgia, Atlanta Division, which was heard before a three-judge court.

On a complaint filed by the appellant herein, he was a plaintiff below, seeking to declare the Civil Rights Act of 1964 un-constitutional and seeking a permanent injunction against the United States and the Attorney General of the United States at that time, Mr. Kennedy, from enforcing that Act against the appellant.

The government filed not only an answer for the counterclaim, and in the counterclaim, asked for an injunction out of provisions for the Civil Rights Act against the appellant.

The case was heard and decision rendered on the counterclaim of the government and the permanent injunction was granted against the appellant and any officers or agents set forth.”


In the opposition, on the side of the United States, attorney Archibald Cox argued, “The fact that the Court is sitting to here — argument on the day that usually bogged only an opening ceremony or occasion, testifies more forcibly that any words in mind can do, to the importance of the issues being presented today.

Civil Rights Act of 1964 is surely the most important legislation enacted in recent decades.

It’s one of the half-dozen most important clauses, I think.

An Act didn’t last century.

No legislation within my memory has been debated as widely as long or as thorough.

Certainly none has been considered more conscientious.”


The opinion in this case was unanimous. Justice Tom Clark wrote the opinion for the court. He wrote, “We therefore conclude that the action of the Congress in the adoption of the Act as applied here to a motel which concededly serves interstate travelers is within the power granted it by the Commerce Clause of the Constitution, as interpreted by this Court for 140 years. It may be argued that Congress could have pursued other methods to eliminate the obstructions it found in interstate commerce caused by racial discrimination. But this is a matter of policy that rests entirely with the Congress, not with the courts. How obstructions in commerce may be removed — what means are to be employed — is within the sound and exclusive discretion of the Congress. It is subject only to one caveat — that the means chosen by it must be reasonably adapted to the end permitted by the Constitution. We cannot say that its choice here was not so adapted. The Constitution requires no more.”

My Opinion:

In this case, I agree with the court decision. Title II of the Civil Rights Act of 1964 clearly forbade racial discrimination in public places having to do with commerce. The Heart of Atlanta Motel refusing to accept African Americans directly violates that act. There shouldn’t be any argument. I believe that the “right” to decide who to accept is far less important than the African Americans that want to stay at the motel.

*Justice Leaning L=Left, LC=Left of Center, C=Center, RC=Right of Center, R=Right