The Heart of Atlanta Motel was located in downtown Atlanta, near an interstate. It accommodated many out- of- state travelers. In fact, eighty percent of the guests were from another state. It emphasized their facilities for conventions and welcomed major corporations and social organizations. This limited their guests to only the white race. Their policy was considered constitutional until the Civil Rights Act of 1964. The Heart of Atlanta Motel continued their policy until it was brought to the authorities" attention. They still believed there was nothing wrong with what they were doing. Specifically the Title II provision. Title II prohibited racial discrimination in places of public accommodation, including motels. The Heart of Atlanta Motel had only been accommodating whites and was not ready to include all races. .
"The recent changes in transportation bought about by the coming of automobiles does not seem of great significance in the problem. People of all races travel today more extensively than in 1878 when this Court first passed upon state regulation of racial segregation in commerce." [At 383].
In 1946 in Morgan v. Virginia Justice Reed observed the growth of interstate travel and suggested that interstate travel discrepancies not be handled by the state. The major section of Title II the Heart of Atlanta Motel violated was: "All persons shall be entitled to the full and equal enjoyment of the goods, services, facilities, privileges, advantages, and accommodations of any place of public accommodation, as defined in this section, without discrimination or segregation on the ground of race, color, religion, or national origin." This seems pretty clear that what the Heart of Atlanta Motel was doing was unconstitutional. The main question was if congress had the power to regulate interstate commerce. .
The reason the United States believed it had control over The Heart of Atlanta Motel was because it violated Title II and it serviced out of state guests.
