Heart of Atlanta Motel v. United States Case Analysis

Heart of Atlanta Motel v. United States Case Analysis
This was an appropriate exercise of
Congressional powers under the
Commerce clause because the two
prongs of the test were met.
Two part test to analyze the exercise of
power by Congress under the Commerce
1. Whether the activity sought to be
regulated is commerce which concerns
more States than one.
This prong is met interstate travel, the
transportation of passengers, and the
modern movement of people concerns more
states than one and is not an open question.
2. Whether there is a real and substantial
relation to the national interest.
Congress has a national interest in
legislating against the disruptive effect that
racial discrimination has on commercial
intercourse (even if this is a moral question).
Rules of Law
Civil Rights Act of 1964 provisions
Section 201(a) 0f the Civil Rights Act states
that all people are entitled to, inter alia,
"accommodations of any place of public
accommodation..." without discrimination
as to color.
Section 201(b)(1) specifically defines a motel
as a covered establishment, "if its operations
affect commerce"
Section 201(c) declares that ‘any inn, hotel,
motel providing lodging to transient guests
affects commerce per se.
Section 203 prohibits withholding any
privilege secured in Sections 201 or 202.
Commerce Clause
Commerce Clause allows Congress to
regulate"commerce with foreign nations,
and among the several states, and with the
Indian tribes.
Current Business Practice Influence
By Holding of this Case
1. The way insurance plans are structured,
to adhere to the ACA.
Importance for Healthcare
This Supreme Court case stripped out some
of the elements of the ACA. The Court held
that Congress exceeded its authority under
the Commerce Clause in the "individual
mandate" section of the ACA (although it
was upheld under Congressional power to
tax). Nat'l Fed'n of Indep. Bus. v. Sebelius,
567 U.S. 519, 132 S. Ct. 2566, 183 L. Ed. 2d
450 (2012)
Subsequent Impact on Caselaw
US v. Lopez Regulation of Gun Free Zones Supreme Court overturned defendant's
conviction for possessing gun in school zone, a violation of the Gun-Free School Zones
Act. The Court held that Congress exceeded its authority (and did not meet prong one of
the test under the Heart of Atlanta Motel v. US test) because the activity to be regulated
did not arise out of and was not connected with a commercial transaction.
United States v. Lopez, 514 U.S. 549, 115 S. Ct. 1624, 131 L. Ed. 2d 626 (1995)
US v. Morrison Similar to US v. Lopez,
Supreme Court struck down the civil
remedy portion of the Violence Against
Women Act (VAWA), saying that Congress
exceeded its authority and "Congress
therefore may not regulate noneconomic,
violent criminal conduct based solely on
the conduct's aggregate effect on
interstate commerce."
United States v. Morrison, 529 U.S. 598,
120 S. Ct. 1740, 146 L. Ed. 2d 658 (2000)
Gonzales v. Raich Congress was within its
authority to ban marijuana (even though CA
permits it) because its an economic activity,
and the government has a number of
interests in regulating the drug
trade/criminal activity.
Gonzales v. Raich, 545 U.S. 1, 125 S. Ct.
2195, 162 L. Ed. 2d 1 (2005)
Congress appropriately passed the
challenged provisions of the Civil Rights Act
under its authority granted by the
Commerce Clause of the Constitution.
Motel had to comply with Civil Rights Act
and serve patrons of color
Heart of Atlanta Motel Original Plaintiff,
Current Appellant
United States, Appellee
Factual Background
Heart of Atlanta ("HOA") is a motel in
Atlanta that is centrally located and solicits
interstate guests 75% of guests are from
out of state.
Prior to Civil Rights Act of 1964, HOA
refused to rent to black individuals.
Procedural History
Heart of Atlanta filed suit in the US
District Court for the Northern
District of Georgia seeking
declaratory judgment and injunctive
relief from the public
accommodations provisions of the
Civil Rights Act. The District Court
denied HOA's request for relief, and
HOA appealed.