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An Introduction to Constitutional Law » Heart of Atlanta Motel v. United States

An introduction to Constitutional Law 100 Supreme Court cases everyone should know

Randy E. Barnett & Josh Blackman

The Heart of Atlanta Motel refused to rent rooms to African-American patrons. Its owner challenged the constitutionality of Title II. He argued that Congress lacked the power to prohibit segregation in a local motel.

The Warren Court unanimously rejected this claim. Justice Clark’s majority opinion was based on the substantial effects test: “[T]he 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.” Clark found that the motel was available to travelers and solicited customers from the national media. Indeed, 75 percent of its guests were from out of state. Therefore, the motel’s segregationist policies, though local, had a substantial effect on interstate commerce.

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