Judicial branch · Landmark case

Heart of Atlanta Motel v. United States

379 U.S. 241 (1964) · Opinion of the Court

DecidedDecember 14, 1964
Vote9–0
AuthorJustice Clark
DispositionCivil Rights Act upheld

What you should know

This page explains the Court’s holding in plain language, where the official text lives, and what to check next.

Supreme Court findings are not news summaries. The controlling document is the Court’s opinion, plus any concurrences or dissents. Use this profile to understand the holding, then verify language, syllabus, and docket history on official sources before relying on a secondary account.

Holding

The Court held that Title II of the Civil Rights Act of 1964, which bans racial discrimination in places of public accommodation, is a valid exercise of Congress’s Commerce Clause power as applied to a motel serving interstate travelers. Because the motel actively solicited and served out-of-state guests, its discrimination against Black travelers had a real, substantial effect on interstate commerce — enough to bring it within Congress’s regulatory reach.

Background

The Heart of Atlanta Motel, a 216-room motel near two interstates, refused to rent rooms to Black customers and advertised nationally for out-of-state guests, roughly 75% of whom came from outside Georgia. Days after the Civil Rights Act of 1964 took effect, the motel sued to block enforcement of Title II, arguing Congress had exceeded its Commerce Clause power and that the law violated the Fifth and Thirteenth Amendments by forcing the owner into “involuntary servitude” to Black customers.

This was the first major test of the new Civil Rights Act to reach the Supreme Court. The Court moved quickly — argued in early October, decided by mid-December — and rejected every argument the motel raised, unanimously upholding the law.

Why this finding matters

The Commerce Clause becomes the constitutional foundation for the Civil Rights Act’s public-accommodations protections.

Rather than relying on the Fourteenth Amendment (which only restrains state action, not private businesses), Congress and the Court used the Commerce Clause to reach private discrimination directly — a strategy this unanimous ruling confirmed was constitutionally sound, clearing the path for the Act to be enforced nationwide.

Vote and authorship

MajorityClark, J. (opinion of the Court)
JoinWarren, C.J., Douglas, Harlan, Brennan, Stewart, White, Goldberg
ConcurrenceBlack, J.; Douglas, J.; Goldberg, J. (each writing separately on the reasoning, not the outcome)
DissentNone

The power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof.

Justice Clark · Heart of Atlanta Motel v. United States

How it fits in government

Legislative branch

This ruling confirmed Congress had the constitutional power to pass Title II’s public-accommodations protections — without this decision, the Civil Rights Act’s enforcement against private businesses would have remained legally uncertain.

Legislative

Judicial branch

The Court applied the same “substantial effects” Commerce Clause reasoning from Wickard v. Filburn to a civil-rights context — showing how one constitutional doctrine can serve very different legislative purposes.

Judicial

Where to verify

Start with the official opinion text, syllabus, and docket materials. Secondary explainers are useful only after the primary record is open.

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