Heart of Atlanta Motel v. United States is the 1964 Supreme Court decision that upheld the public accommodations section of the Civil Rights Act of 1964. In a unanimous ruling issued on December 14, 1964, the Court held that Congress had the power under the Commerce Clause to prohibit racial discrimination by hotels, motels, and similar businesses that serve interstate travelers. The case arose when the owner of a large Atlanta motel sued to block the new law so he could keep refusing rooms to Black guests. He lost on every argument he raised.
The Motel and the Lawsuit
The Heart of Atlanta Motel was a 216-room facility in downtown Atlanta, sitting near Interstates 75 and 85. It advertised in national magazines and on highway billboards, and about 75 percent of its registered guests came from outside Georgia.1Supreme Court of the United States. U.S. Reports: Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964) Despite that reliance on interstate traffic, the motel refused to rent rooms to Black travelers.
President Lyndon Johnson signed the Civil Rights Act on July 2, 1964. The motel’s owner, Moreton Rolleston Jr., filed suit almost immediately, asking a federal court to declare Title II unconstitutional and to block its enforcement. The government countersued for an order requiring the motel to stop discriminating. A three-judge district court sided with the government, upheld the Act, and entered a permanent injunction. Rolleston appealed directly to the Supreme Court.2Justia. Heart of Atlanta Motel, Inc. v. United States
What Title II Required
Title II of the Civil Rights Act, codified at 42 U.S.C. § 2000a, bars discrimination based on race, color, religion, or national origin in businesses that serve the public and whose operations touch interstate commerce. Hotels, restaurants, and theaters all fall within its reach.3Office of the Law Revision Counsel. 42 USC 2000a – Prohibition Against Discrimination or Segregation in Places of Public Accommodation For lodging, the law reaches any hotel or motel providing rooms to travelers, with a narrow carve-out for owner-occupied buildings of five or fewer rental rooms.4Office of the Law Revision Counsel. 42 USC 2000a – Prohibition Against Discrimination or Segregation in Places of Public Accommodation
What Rolleston Argued
Rolleston attacked the Act on three constitutional grounds. First, he argued Congress had exceeded its Commerce Clause authority because renting motel rooms was a local matter, not interstate commerce. Second, he claimed the law violated the Fifth Amendment by depriving him of the liberty to choose his customers and use his property as he wished. Third, and most unusually, he invoked the Thirteenth Amendment, arguing that forcing a business owner to serve people against his will amounted to involuntary servitude.1Supreme Court of the United States. U.S. Reports: Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964)
The Court’s Ruling
Justice Tom C. Clark wrote the opinion for a unanimous Court. Title II was a valid exercise of the commerce power, and the district court’s injunction was affirmed.1Supreme Court of the United States. U.S. Reports: Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964)
The Commerce Clause reasoning did the heavy lifting. Before passing the Act, Congress had built a substantial evidentiary record. Witnesses testified that Black Americans routinely drove long distances without being able to find lodging, relied on friends for overnight housing, or consulted a special guidebook listing establishments that would accept them. The Under Secretary of Commerce testified that the problem was nationwide, not confined to the South.2Justia. Heart of Atlanta Motel, Inc. v. United States
The Court drew on the aggregate-effects principle from Wickard v. Filburn (1942), which held that Congress may regulate purely local activity when, taken together across the country, it has a substantial effect on interstate commerce.5Justia. Wickard v. Filburn One motel turning away Black guests might look like a local matter, but thousands of businesses doing the same thing created a real barrier to interstate travel. And the Heart of Atlanta itself was a poor vehicle for a local-activity argument, since three-quarters of its guests crossed state lines to reach it.
Clark dispatched the other two claims in short order. Requiring a business open to the public to actually serve the public is not a taking of property, and Congress has long been permitted to impose reasonable regulations on commercial activity without running afoul of Fifth Amendment due process. As for the Thirteenth Amendment argument, the Court noted that 32 states already required innkeepers to serve all comers, and those laws simply codified an English common-law duty predating the amendment by centuries. If that centuries-old obligation was not involuntary servitude, neither was Title II.2Justia. Heart of Atlanta Motel, Inc. v. United States
The Concurrences
Justices William O. Douglas and Arthur Goldberg agreed with the outcome but wrote separately to argue the case should have been decided under Section 5 of the Fourteenth Amendment, which gives Congress power to enforce equal protection. Douglas worried that grounding civil rights protections in the Commerce Clause invited unnecessary future litigation over whether a given business affected interstate commerce. He argued the right to equal access in public places is a constitutional guarantee against state-supported discrimination, not merely an incident of commercial regulation. Both justices were concerned that a Commerce Clause foundation sent the wrong message about why Black Americans were entitled to equal treatment. The majority stayed with the Commerce Clause because Congress had explicitly relied on it in passing the Act.
The Companion Case
The Court decided Katzenbach v. McClung the same day. That case applied the same reasoning to Ollie’s Barbecue, a family-owned restaurant in Birmingham with a local clientele but a substantial share of food that had moved through interstate commerce. The Court unanimously held that this connection was enough to bring the restaurant within Title II.6Oyez. Katzenbach v. McClung Between the two decisions, virtually any Commerce Clause challenge to Title II was foreclosed. A motel drawing most of its guests from out of state was covered, and so was a neighborhood restaurant buying interstate food.
Why the Case Still Matters
The immediate effect was concrete: a Black traveler passing through Atlanta could stop at the Heart of Atlanta Motel and get a room. The broader effect was doctrinal. By upholding federal regulation of a single motel on the theory that discrimination in the aggregate burdened interstate commerce, the Court expanded the practical reach of the Commerce Clause and confirmed the Wickard principle in a high-profile civil rights setting.
The decision also shaped how Congress wrote later civil rights and anti-discrimination laws. Rather than relying on the Fourteenth Amendment, which requires showing state involvement, Congress kept using the Commerce Clause as its primary source of authority for reaching private conduct. The concern Douglas and Goldberg raised in 1964, that this framing tied equal treatment to commercial value, remained part of the academic debate. The framing itself remained the standard legislative strategy for decades of federal civil rights legislation.