Question

Heart of Atlanta Motel v. United States

“One need only examine the evidence which we have discussed . . . to see that Congress may . . . prohibit racial discrimination by motels serving travelers, however ‘local’ their operations may appear.”
—Clark, Justice

The Heart of Atlanta Motel, located in the state of Georgia, had 216 rooms available to guests. The motel was readily accessible to motorists using U.S. interstate highways 75 and 85 and Georgia state highways 23 and 41. The motel solicited patronage from outside the state of Georgia through various national advertising media, including magazines with national circulation. Approximately 75 percent of the motel’s registered guests were from out of state. The Heart of Atlanta Motel refused to rent rooms to blacks.

Congress enacted the Civil Rights Act of 1964, which made it illegal for motels, hotels, and other public accommodations to discriminate against guests based on their race. After the act was passed, the Heart of Atlanta Motel continued to refuse to rent rooms to blacks. The owner-operator of the motel brought an action in U.S. district court, Heart of Atlanta Motel v. United States, to have the Civil Rights Act of 1964 declared unconstitutional. The plaintiff argued that Congress, in passing the act, had exceeded its powers to regulate interstate commerce under the Commerce Clause of the U.S. Constitution.

The U.S. Supreme Court held that the provisions of the Civil Rights Act of 1964 that prohibited discrimination in accommodations were constitutional as a proper exercise of the commerce power of the federal government. The U.S. Supreme Court stated,

The power of Congress over interstate commerce is not confined to the regulation of commerce among the states. It extends to those activities intrastate which so affect interstate commerce or the exercise of the power of Congress over it as to make regulation of them appropriate means to the attainment of a legitimate end, the exercise of the granted power of Congress to regulate interstate commerce.
Heart of Atlanta Motel v. United States, 379 U.S. 241, 85 S.Ct. 348, 1964 U.S. Lexis 2187 (Supreme Court of the United States

Why was this case so important? Why did the U.S. Supreme Court develop the “effects on interstate commerce” test? Is most commerce considered “interstate commerce” that can be regulated by the federal government?

Answer 1

This case is important because it was a landmark decision that was passed by the US Supreme Court that held that the Commerce Clause gave the U.S. Congress a power to make private business entities abide by the Title II of the Civil Rights Act of 1964. This case is important because the landmark decision that was passed in it served as a turning point with regards to efforts of Congress to promote civil rights by making use of its power to regulate interstate commerce.

The “effects on interstate commerce” test was developed by the Supreme Court so as to ensure that Congress will be able to regulate interstate commerce in cases where the nature of the clientele is mobile. The test ensured that Congress had the power to regulate the motel as its business was related to interstate commerce. The test laid grounds that Congress has power not only with regards to regulation of commerce but also with regards to those activities that affect interstate commerce or the exercise of power of Congress. The Supreme Court developed the test to see when Congress regulates an intrastate economic/commercial activity does this regulated activity have a substantial economic effect on intrastate commerce.

No, most commerce is not considered ‘interstate commerce’ that can be regulated by the federal government. When intrastate commerce does not so much affect interstate commerce and/or the exercise of power of Congress over it then it will not be considered interstate commerce. It should be noted that as long as intrastate commercial activities and businesses do not have restrictive laws (and hence are not at odds with federal legislation) they will not be regarded as interstate commerce.