Heart of Atlanta Motel (1956-1976)

The site of one of the most important civil rights cases in US History, the Heart of Atlanta Motel stood at 255 Courtland Street from 1956-1976. The owner of this 216-room hotel, Moreton Rolleston Jr., continued to refuse to serve Black customers following the passage of the 1964 Civil Rights Act which banned racial discrimination in places of public accommodation. Rolleston maintained that the 1964 law was unconstitutional because he believed it violated his right to operate his business as he chose. The Supreme Court upheld the Civil Rights Act and ruled against Rolleston, maintaining that his actions were not protected by the 5th Amendment and violated the 14th Amendment's guarantee of equal protection of law. The Heart of Atlanta was demolished and replaced by the Hilton Atlanta in 1976.

After President Lyndon B. Johnson signed the Civil Rights Act on July 2, 1964, hotel owner and attorney Moreton Rolleston Jr., who had previously refused to accept Black customers at the Heart of Atlanta Motel, filed suit in federal district court in an attempt to challenge the new law that barred racial discrimination in places of public accommodation. Rolleston's suit alleged that the government's prohibition of racial discrimination contained in Title II of the Civil Rights Act represented an invalid exercise of Congress’s power to regulate interstate commerce. 

Rolleston argued that his operation of his motel did not interstate commerce. More to the point, he also claimed that the 1964 law violated the Fifth Amendment’s guarantee of due process and just compensation for the taking of private property because the civil rights law prevented him from operating his business as he choose. He even argued that because the law forced him to serve Black customers, it was a violation of the Thirteenth Amendment’s prohibition of involuntary servitude. While this claim was easily discarded, Rolleston's argument about the rights of business owners had precedent. In 1883, the Supreme Court cited the rights of business owners to deny service in their decision which invalidated the Civil Rights Act of 1875. Between that 1883 decision and the 1964 Civil Rights Act, segregation was legal in many states and legally mandated in others.   

The district court upheld the constitutionality of Title II and issued a permanent injunction requiring the motel to cease discriminating against Black customers. Enraged with this decision, Rolleston appealed to the Supreme Court. Oral arguments were heard on Oct. 5, 1964 in the case of Heart of Atlanta Motel, Inc. Vs. Us. 379 U.S. 241 (1964).

In a unanimous (9–0) ruling issued on December 14, the Supreme Court affirmed the district court’s finding. The 9-0 decision sent a clear message of the Court’s decision that segregation was a violation of the 14th Amendment and state laws that required or allowed racial segregation were no longer valid. The Court concluded that places of public accommodation had no "right" to deny service on the basis of race. In his opinion for the Court, Justice Tom C. Clark also argued that the motel was subject to federal jurisdiction under the Interstate Commerce Clause. The justices also rejected the petitioner’s arguments that the 1964 law violated the Thirteenth Amendment as a misguided view of history.  

Rolleston later sold his hotel for $11 million. When interview after the case, Rolleston said that this legislation would have “some adverse effect” on Southern businesses. He maintained his opposition to racial integration and was later disbarred in 2007 as a result of his behavior during a property rights dispute with African American actor Tyler Perry. 

"Heart of Atlanta Motel v. United States." Encyclopædia Britannica. Accessed October 31, 2016. http://www.britannica.com/EBchecked/topic/258476/Heart-of-Atlanta-Motel-v-United-States

"In the Matter of Moreton Rolleston," Jr. FindLaw.com. Accessed October, 2016. http://caselaw.findlaw.com/ga-supreme-court/1338105.html

WSB-TV newsfilm clip of attorney Moreton Rolleston. Civil Rights Library. Accessed October 31, 2016. http://crdl.usg.edu/export/html/ugabma/wsbn/crdl_ugabma_wsbn_31715.html?Welcome