Heart of Atlanta Motel v. United States

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Heart of Atlanta Motel v. United States, 379 U.S. 241, brought forth the question: in passing the Civil Rights Act in 1964 did Congress exceed the Commerce Clause by depriving the owners of the Heart of Atlanta Motel to the right to choose their own customers?

In 1964 the owners of the Heart of Atlanta Motel in Atlanta, Georgia were charged with violating Title II of the Civil Rights Act by refusing to accommodate African-Americans in their facility. They claimed that Congress had overstepped their constitutional powers in forcing them to serve customers in their privately owned business whom they did not wish to serve. When the case was brought before the Supreme Court they ruled in a unanimous vote that the motel must acknowledge all persons as customers despite racial differences. The court noted that the relevance of Title II was "carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people. . ." The Court concluded that places of public accommodation had no right to withhold services from certain guests as they saw fit with no consequences from governmental regulations.

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