Heart of Atlanta Motel and civil rights

PG posted this photo in one of his collections at Chamblee54:

Heart of Atlanta Motel, 1956 - Special Collections and Archives,Georgia State University Library

I wondered whether this is the motel in the case testing the 1964 Civil Rights Act — and sure enough, it is.  The case was decided, finally, by the U.S. Supreme Court in 1964, Heart of Atlanta Motel, Inc., v. United States, 379 U.S. 241 (1964) .

This important case represented an immediate challenge to the Civil Rights Act of 1964, the landmark piece of civil rights legislation which represented the first comprehensive act by Congress on civil rights and race relations since the Civil Rights Act of 1875. For much of the 100 years preceding 1964, race relations in the United States had been dominated by segregation, a system of racial separation which, while in name providing for “separate but equal” treatment of both white and black Americans, in truth perpetuated inferior accommodation, services, and treatment for black Americans.

During the mid-20th century, partly as a result of cases such as Powell v. Alabama, 287 U.S. 45 (1932); Smith v. Allwright, 321 U.S. 649 (1944); Shelley v. Kraemer, 334 U.S. 1 (1948); Sweatt v. Painter, 339 U.S. 629 (1950); McLaurin v. Oklahoma State Regents, 339 U.S. 637 (1950); NAACP v. Alabama, 357 U.S. 449 (1958); Boynton v. Virginia, 364 U.S. 454 (1960) and probably the most famous, Brown v. Board of Education of Topeka, 347 U.S. 483 (1954), the tide against segregation began to turn. However, segregation remained in full effect into the 1960s in parts of the southern United States, where the Heart of Atlanta Motel was located, despite these decisions.

The Atlanta Time Machine, a great collection of photos in the history of Atlanta and Georgia, has more photos, and this description of the site:

The Heart of Atlanta motel, located at 255 Courtland Street NE, was owned by Atlanta attorney Moreton Rolleston Jr.  Rolleston, a committed segregationist, refused to rent rooms at his hotel to black customers.  Upon passage of the Civil Rights Act of 1964, Rolleston immediately filed suit in federal court to assert that the law was the result of an overly broad interpretation of the U.S. Constitution’s commerce clause.  Rolleston represented himself in the case, HEART OF ATLANTA MOTEL, INC. v. UNITED STATES ET AL., which  went all the way to the United States Supreme Court.  Rolleston lost when the Supreme Court ruled that Congress was well within its powers to regulate interstate commerce in such a manner.  The Hilton Hotel now stands on the former site of the Heart of Atlanta Motel.

Texts in law school rarely have illustrations.  I know the motel mostly as a citation on pages of text, great grey oceans of somnambulent text.  This case is important in civil rights, though it is mentioned almost never in history texts.  What are these cases really about?  These photos offer us insight.

The Heart of Atlanta Motel aspired to greatness in the late 1950s and 1960s — evidenced by this publicity flyer photo from the Atlanta Time Machine; notice the flag flying for the motel’s Seahorse Lounge (Atlanta is landlocked):

Heart of Atlanta Motel publicity photo - Atlanta Time Machine; not just a podunk "motor lodge," but a "resort motel." Click for larger image.

For the 1960s, this place offered great amenities, including two swimming pools and in-room breakfast service.

Flyer for the Heart of Atlanta Motel, circa 1960 - Atlanta Time Machine image

This photo is amusing — I can just imagine the difficulties of launching a motor boat of this size in one of the swimming pools, obviously for a publicity stunt.  The photo is dated February 27, 1960, in the Pullen Library Collection.

Boat in the pool at the Heart of Atlanta Motel, 1960 - Atlanta Time Machine image

To compare how times have changed, you may want to look at this aerial photo of the area, including the Heart of Atlanta Hotel, and compare it with modern photos which show the Hilton Hotel that replaced the property.

Rolleston appears to have had a big ego.  As noted above, he represented himself in this case, and he argued it in the Supreme Court.  Here’s a picture from about that time, from the University of Missouri-Kansas City Law School “Famous Trials” site:

Moreton Rolleston, Jr., owner of the Heart of Atlanta Motel and the attorney who argued the case at the Supreme Court - UMKC Law School image; photo: Wayne Wilson/Leviton-Atlanta

You may decide for yourself whether this fits the old legal aphorism that a lawyer who represents himself in a case has a fool for a client.  The Oyez site at the University of Chicago provides access to the audio of the oral arguments.  Did Rolleston argue ably?  Rolleston argued against Archibald Cox, who went on to fame in the Watergate scandals.  This appears to have been Rolleston’s only appearance before the Supreme Court; it was Cox’s ninth appearance (he argued 20 cases before the Court in his career, several well known and notable ones).

Heart of Atlanta vs. United States was argued on October 5, 1964.  The opinion was issued on December 14, 1964, a 9-0 decision against Rolleston and segregation authored by Justice Tom C. Clark (one of Dallas’s earliest Eagle Scouts).

This was a fight Mr. Rolleston picked.  He was not cited nor indicted for violation of the Civil Rights Act, but instead asked for an injunction to prevent the law’s enforcement; according to the published decision,

Appellant, the owner of a large motel in Atlanta, Georgia, which restricts its clientele to white persons, three-fourths of whom are transient interstate travelers, sued for declaratory relief and to enjoin enforcement of the Civil Rights Act of 1964, contending that the prohibition of racial discrimination in places of public accommodation affecting commerce exceeded Congress’ powers under the Commerce Clause and violated other parts of the Constitution. A three-judge District Court upheld the constitutionality of Title II, §§ 201(a), (b)(1) and (c)(1), the provisions attacked, and, on appellees’ counterclaim, permanently enjoined appellant from refusing to accommodate Negro guests for racial reasons.

Oyez summarizes the case question:

Facts of the Case 

Title II of the Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce. The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans and was charged with violating Title II.

Question 

Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers?

The decision turned on the commerce clause, and the reach of Congressional power to regulate interstate commerce.

Decision: 9 votes for U.S., 0 vote(s) against
Legal provision: Civil Rights Act of 1964, Title II

The Court held that the Commerce Clause allowed Congress to regulate local incidents of commerce, and that the Civil Right Act of 1964 passed constitutional muster. The Court noted that the applicability of Title II was “carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people. . .” The Court thus concluded that places of public accommodation had no “right” to select guests as they saw fit, free from governmental regulation.

Good decision.

Heart of Atlanta Motel is gone.  The site is occupied by the Hilton Atlanta, today.