Moreton Rolleston Case Summary

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In 1964, the owner of the Heart of Atlanta Motel, Moreton Rolleston, challenged the constitution of the Civil Rights Act only months after Act’s passing by filing a suit against the federal government. After a lengthy fight, the Supreme Court ruled that under the Constitution’s Commerce Clause, the federal government had the right to desegregate the Heart of Atlanta Motel.
In Title II of the Civil Rights Act, public accommodations involved with interstate commerce are prohibited from discriminating against customers based on race, sex, skin color, religion, or national origin. Rolleston accused said Act of being unconstitutional because it violated the Fifth Amendment’s guarantees of due process and just compensation for the taking of private property by stripped him of the right to choose his clientele, violated the Thirteenth Amendment’s prohibition of involuntary servitude by forcing him to rent rooms to black clientele, and exceeded the federal government’s powers of commerce regulation in general.
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The case made it onto the Supreme Court’s docket and oral arguments were heard on October 5, 1964. The United States argued that Rolleston could not deny black people the right rent rooms in his motel despite the Heart of Atlanta being private property because it interfered with the flow of interstate commerce, and according to the Constitution’s Commerce Clause, the federal government has the power to enforce the Civil Rights Act because in order to protect and maintain said flow. Rolleston firmly held onto his original argument of the Civil Rights Act violating his Fifth and Thirteenth Amendments rights and the federal government was wrongly overstepping its powers of commerce