Law School Case Brief
Heart of Atlanta Motel, Inc. v. United States - 231 F. Supp. 393 (N.D. Ga. 1964)
The power of Congress, when that body seeks to occupy the full extent of its powers under the U.S. Constitution, extends to those activities intrastate which so affect interstate commerce as to make regulation of them appropriate means to the exercise of the grant of power of Congress to regulate interstate commerce. The initial determination of whether the challenged regulation is such "appropriate means" is for Congress. Courts may not overturn such determination unless they conclude that under no reasonable theory could Congress find them "appropriate to the attainment" of its power to regulate commerce.
Plaintiff Heart of Atlanta Motel, Inc. ("Motel") filed an action in federal district court against defendants United States and Robert F. Kennedy, as the Attorney General of the United States (collectively, "Government"), seeking to enjoin the Government from exercising the powers granted under the Civil Rights Act of 1964, 42 U.S.C.S. § 1971, and to recover damages allegedly resulting from a partial taking of the Motel's property without just compensation. By counterclaim, the Government sought to enjoin the Motel from discriminating on the basis of race regarding the availability of its accommodations.
Did the Government possess the authority to regulate the commercial activities of the Motel?
The court granted the Government's request for an injunction and prohibited the Motel from refusing to accept African-Americans as guests in the Motel by reason of their race or color and from making any distinction whatever upon the basis of race in the availability of the goods, services, facilities, privileges, advantages or accommodations offered or made available to the guests of the Motel. The court held that the power of Congress extended to those intrastate activities that so affected interstate commerce as to make regulation of the activities appropriate under the interstate commerce clause. The Civil Rights Act of 1964, the court ruled, was a constitutional use of the Congress' power to regulate interstate commerce. The court further held that the Motel's claim for damages for unjust taking alleged no grounds for relief.
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