## Facts

- Heart of Atlanta Motel, Inc. operated a 216-room motel in Atlanta, Georgia, near major interstate highways and solicited patrons through national advertising and extensive roadside signage.
- Approximately 75% of the motel’s registered guests were from outside Georgia.
- The motel refused to rent rooms to Black customers and stated its intent to continue that practice.
- After Title II of the Civil Rights Act of 1964 barred racial discrimination in covered public accommodations whose operations affected commerce, the motel sought to block enforcement as applied to it.

## Issues

1. Whether Title II of the Civil Rights Act of 1964, as applied to a motel serving interstate travelers, exceeded Congress’s power under the Commerce Clause.
2. Whether Title II violated the Fifth Amendment by depriving the motel of property or liberty without due process (including a claimed right to select customers).
3. Whether Title II imposed involuntary servitude in violation of the Thirteenth Amendment by requiring the motel to serve Black guests.

## Decision

- The Supreme Court unanimously affirmed the judgment upholding Title II as applied to the motel.
- The Court held that Congress validly regulated the motel under the Commerce Clause because the interstate movement of persons is commerce and the motel’s operations substantially affected interstate travel.
- The Court held Title II did not violate the Fifth Amendment’s due process protections.
- The Court held Title II did not constitute involuntary servitude under the Thirteenth Amendment.
- The injunction permanently barring the motel from refusing Black guests for racial reasons was sustained.

## Legal Principles

- Congress may regulate local conduct that has a substantial and harmful effect on interstate commerce, including discrimination in public accommodations that burdens interstate travel.
- The interstate movement of persons is within the scope of “commerce,” and Congress may protect that commerce even when the travel is not itself commercial.
- A statute directed at eliminating burdens on interstate commerce is not unconstitutional merely because Congress also sought to address moral or social harms.
- Reasonable federal regulation of businesses affecting interstate commerce that limits discriminatory customer selection does not, without more, deprive owners of property or liberty without due process.
- Requiring a business to provide nondiscriminatory service in commercial operations is not “involuntary servitude” within the meaning of the Thirteenth Amendment.

## Conclusion

The Court upheld Title II’s application to a motel that served and solicited interstate travelers, ruling that Congress could bar racial discrimination in such public accommodations under the Commerce Clause and that the statute did not violate the Fifth or Thirteenth Amendments.


Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964)