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Atlanta Motel Case Study

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Heart of Atlanta Motel, Inc. v. United States
379 U.S. 241 (1964)
Facts
A case concerning the commerce clause use to combat moral wrongs. Title II of the Civil Rights Act of 1964 prohibited racial discrimination by certain public accommodations that operated in or affected interstate commerce. Following the passing of the 1964 Civil Rights Act, the owner of the Heart of Atlanta Motel challenged its constitutionality, arguing that the requirements of the act exceeded the authority granted to Congress over interstate commerce. The motel refused to rent rooms to black patrons. The federal district court United States ruled in favor of the United States and issued a permanent injunction requiring the Heart of Atlanta Motel, Inc. to refrain from
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Holding
Yes. 9-0 in favor of the United States. Justice Clark wrote the unanimous opinion.

Reasoning
1. Discrimination by hotels impedes interstate travel. The determinative test for Congress’ power under the commerce clause is whether the activity is commerce that concerns more than one state and has a real and substantial relation to then national interest.
2. Congress is not restricted in regulating interstate commerce just because the commerce it is dealing with was also deemed a moral and social wrong. The power to regulate commerce includes the power to regulate the local incidents that may have a substantial effect on commerce. Congress can adopt the Civil Rights Act of 1964 to apply to a motel that serves interstate travelers under the Commerce Clause.
3. The district court decision is affirmed.

Concurrences/Dissents
N/A

Analysis
This case expanded the power of Congress to use the Commerce Clause to regulate moral wrongs that occur in interstate commerce. While I agree with the opinion of the majority and the reasoning therein, I am hesitant to accept that this decision will allow Congress too much authority to regulate interstate commerce and infringe on the sovereignty of states, subverting the Tenth Amendment in the
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