While the Commerce Clause applies in this case, the decision to rid the nation of racial discrimination should be found in a constitutional principle that deals with more than the interstate movement of cattle, fruit, and steel. On the same day, the Supreme Court heard challenges to Title II from a motel owner and from Ollie McClung. Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241 (1964), was a landmark decision of the US Supreme Court holding that the Commerce Clause gave the U.S. Congress power to force private businesses to abide by Title II of the Civil Rights Act of 1964, which prohibits discrimination in public accommodations.[1]. Both claimed that the federal government had no right to impose any regulations on small, private businesses. A three-judge panel of the District Court for the Northern District of Georgia upheld the constitutionality of the Civil Rights Act, and enjoined the Motel owner from discriminating against African American patrons. Ollie McClung's restaurant, Ollie's Barbecue, was a family-owned restaurant that operated in Birmingham, Alabama, and seated 220 customers. It was located on a state highway and was 11 blocks from an interstate highway. Following is the case brief for Katzenbach v. McClung, 379 U.S. 294 (1964) Using that as the Constitutional basis would obviate an analysis of whether a particular private business affects, or does not affect, interstate commerce. One section of the act, Title II, was specifically intended to grant African-Americans full access to public facilities such as hotels, restaurants, and public recreation areas. The movement of persons between the States is “commerce,” and racial discrimination has a disruptive effect on that interstate commerce. https://supreme.justia.com/cases/federal/us/379/241/case.html. In section 2 of the opinion, the Court agreed with McClung that Ollie's itself had virtually no effect on interstate commerce. The judgment of the District Court for the Northern District of Georgia is affirmed.

It held that the Commerce Clause gives Congress the authority to mandate that private businesses that serve the public cannot discriminate based on race. [4], Cox also highlighted how discrimination by hotels and motels hinders interstate travel by limiting the availability of accommodations for travelers. Therefore, a hotel or motel does not necessarily engage in interstate commerce because the profit comes from persons rather than goods. For much of the 100 years preceding 1964, African Americans in the United States had been dominated by racial segregation, a system of racial separation which, while in name providing for "separate but equal" treatment of both white and African Americans, in deed provided inferior accommodation, services, and treatment for African Americans. Thus, the Act is enforceable against both the Heart of Atlanta Motel and the barbecue restaurant. v. Varsity Brands, Inc. A large motel in Atlanta refused to serve African Americans.