With the Commerce Clause, Congress ended racial discrimination in motels with Heart of Atlanta Motel v. United States (1964).
Heart of Atlanta Motel v. United States has some interesting facts. Before the Civil Rights Act of 1964, the Heart of Atlanta Motel only rented rooms to whites. Eventually, Hearts of Atlanta Motel (Appellant) challenged the constitutionality of the Act when it had to comply with Title 2 of the Act.
Here’s the issue before the Supreme Court: Can Congress use the commerce clause to stop racial discrimination in private businesses?
This case established the following rule: In regards to regulating interstate commerce, Congress can regulate private businesses to prohibit racial discrimination.
Prior to 1964, Congress tried to end racial discrimination. In the Civil Rights cases of 1875, the Supreme Court said Congress cannot end private discrimination with the Fourteenth Amendment since that only applies to states. Separate but equal facilities would continue for 89 years.
When ending racial discrimination, Congress could use the commerce clause. In Wickard v. Filburn, the Court said Congress can regulate any economic activity that has a substantial effect on interstate commerce. Since racial discrimination in the aggregate impacted commerce across the USA, Congress could use the commerce clause to regulate private discrimination. In the past, Congress used the commerce clause to regulate the amount of wheat a farmer grew in Wickard v. Filburn. Again, Congress could use the commerce doctrine to regulate private discrimination.
Overall, this case would start off a series of cases to address the issue of civil rights violations in the 1960s. This case addressed discrimination in motels. There would be other Supreme Court cases that dealt with private discrimination in restaurants in the United States. By the end of the ’60s, the Supreme Court had made a good start in addressing civil rights violations in private businesses.