Heart of Atlanta Motel, Inc. v. United States (1964)

The Civil Rights Act of 1964 prohibited places of “public accommodation” from discrimination based on customers' race, sex, color, religion, or national origin. The Heart of Atlanta Motel challenged the constitutionality of this provision and, after losing before a three-judge federal court, appealed to the Supreme Court.

The Supreme Court ruled that Congress had the power under the Commerce Clause to enact the prohibitions on discrimination contained in the public accommodations section of the Civil Rights Act of 1964. Justice Thomas Clark wrote the opinion for a unanimous Court. He reviewed testimony presented at congressional hearings showing that Americans had become increasingly mobile, but that African Americans were discriminated against by hotels and motels, and often had to travel longer distances to get lodging or had to call on friends to put them up overnight.

Justice Clark noted that under the Interstate Commerce Act, “…the power of Congress to promote interstate commerce also includes the power to regulate the local incidents thereof, including local activities in both the States of origin and destination, which might have a substantial and harmful effect upon that commerce. One need only examine the evidence which we have discussed above to see that Congress may—as it has—prohibit racial discrimination by motels serving travelers, however 'local' their operations may appear.”

Justice Clark also found that the Act did not deprive the motel owner of liberty or property under the Fifth Amendment. Because Congress has the right to prohibit discrimination in accommodations under the Interstate Commerce Act, the motel “has no 'right' to select its guests as it sees fit, free from governmental regulation.”

President John F. Kennedy proposed the Civil Rights Act as a step toward ending discrimination based on race, color, religion, or national origin. President Lyndon B. Johnson eventually obtained passage of an even stronger version of the act. In addition to the provisions of Title II dealing with public accommodation at issue in Heart of Atlanta Motel, the Act also covers equal voting rights and discrimination by trade unions, schools, or employers, requires desegregation of public schools, and prohibits discrimination in the distribution of funds under federally assisted programs.

Title II of the Civil Rights Act contains a specific exemption for private clubs or other establishments which are not open to the public. Many cases have considered whether particular organizations are in fact private within the meaning of this law. For example, courts have ruled that YMCAs were not private clubs and that their rental of rooms brought them within the public accommodations provisions of Title II.

In Boy Scouts of America v. Dale, 2000, the Supreme Court considered whether New Jersey's public accommodations law could require the Boy Scouts to accept a gay man as an assistant scoutmaster. The Court found that the Boy Scouts is a private organization and ruled that a State may not require a private group to take actions or express points of view contrary to their own beliefs. New Jersey's public accommodations law infringed the Boy Scouts' freedom of expressive association and interfered with their right to oppose homosexual conduct.