Heart of Atlanta Motel v. United States
The 1964 case Heart of Atlanta Motel v. United States sought to shield the motel owner from having to rent rooms to Black patrons, claiming that the Civil Rights Act overstepped the authority of Congress to regulate interstate commerce.
The case became known as a test of the Civil Rights Act of 21964, which had only been in place a few months when the Heart of Atlanta case was filed.
The motel owner also claimed his Fifth Amendment right allowed him to do business with those he chose. He also claimed the Thirteenth Amendment protected him from involuntary servitude, which would take place if he had to rent rooms to Blacks. U.S. District Court sided with the defendant, represented by the U.S. attorney. When it was selected by the Supreme Court, the Heart of Atlanta case was combined with another case protesting the Civil Rights Act, this one a restaurant, also in Georgia, which also refused to accommodate Blacks.
The Court determined that the motel in question was in the business of interstate commerce due to its proximity to Interstate highways as well as state highways, and that about 75 percent of its business was out-of-state guests, therefore making the Interstate Commerce aspect of the Civil Rights Act applicable. The Court threw out the motel owner’s assertion about the Thirteenth Amendment, saying it was not applicable.
Similarly, the owner of Ollie’s Barbecue near Birmingham, Alabama, sought to test the authority of Congress to regulate interstate commerce through the Civil Rights Act. After successfully getting an injunction to stop the “interference” with his business from a District Court judge, the Supreme Court took up the case. In Katzenbach v. McClung, the defendant, the barbecue restaurant owner, claimed the Congress had no business regulating his “small, private” restaurant. But again, the court determined that a significant portion of the restaurant’s business was generated by the nearby interstate and further, that many Black motorists patronized the business (but were only allowed take-out, not in-house seating). The court upheld the interstate commerce aspect of the Civil Rights Act.