Heart of Atlanta Motel v. United States was a landmark case in which the Supreme Court of the United States bestowed upon the US Congress the power to compel private businesses to adhere to Title II of the Civil Rights Act 1964, which prohibits racial discrimination in public places or business establishments. This case was quite important not only because it asserted the role of the Congress in enhancing racial equality in America but also because it defined the scope of the powers of the US Congress under the Commerce Clause, especially the power of the Congress to regulate intervenes, albeit to a limited extent in the regulation of interstate commerce.

By upholding the ruling that the Congress may in exercise of its authority under the Commerce Clause prohibit discrimination in public accommodation was an important milestone in the history of civil rights movement and the clamor for racial equality. A contrary decision in this case would have effectively invalidated the Civil Rights Act of 1964, leaving the states at liberty to enact varied laws to safeguard against racial discrimination. The impact of this decision on the American legal landscape was therefore to create a standard or guiding applicability of the Commerce Clause (US Constitution, Article 1, Section 8, and Clause 3) (Casenotes. (2007).

Previous decisions prior to this ruling had tended to limit the effect of Commerce Clause on private business. The Fourteenth Amendment had prohibited racial discrimination by states but the law appeared silent on acts of racial discrimination by private businesses such as motels and restaurants. Long after the enactment of the Civil Rights Act of 1875, private businesses still enjoyed the liberty to deny access or refuse to serve African Americans, especially after the Supreme Court ruled in a number of civil rights cases in 1883 that Congress had limited jurisdiction over private discrimination (Miller, 2009). These rulings dealt the Fourteenth Amendment a significant blow by limiting the powers of the Congress and that of the federal government to reign in on private discrimination.

In this particular case, the noted that the power of the US Congress to regulate interstate commerce transcends the regulation of commerce among states to those activities interstate, which affect interstate commerce or the powers of the congress thereof, which require the intervention of the Congress in achieving the legitimate end of the exercise of its power to regulate interstate commerce. The Supreme Court in its ruling develops a test for the effects of Commerce Clause and the Civil Rights Act of 1964 on interstate commerce. The effect of this test was that the Congress had the power to prohibit racial discrimination by private businesses however local their operations seemed to be as long as the nature of the business served interstate purposes such as accommodating travellers who do not necessarily hail from the state of Georgia (Miller, 2009).

Most commerce is considered interstate because business premises do not often restrict their clientele to specific states as that would in itself constitute acts of hostility between states. In this case for instance, the motel offered accommodation to travellers from Georgia and those from other states, making its clientele diverse and interstate as opposed to being intrastate (Miller, 2014). Commerce is not always about the movement of commodities and services but also about the movement and interaction of people. Unlike goods or services, people are not limited to states and will in most cases shuttle between states in pursuit of business objectives. This makes commerce mostly interstate within the confines of the Commerce Clause.