December 14th, 1964

U.S. Supreme Court Upholds Law Prohibiting Racial Discrimination in Private Hotels

The Heart of Atlanta Motel, owned by committed segregationist Moreton Rolleston, Jr., opened for business in Atlanta, Georgia, on September 5, 1956. From that time, the 216-room hotel steadfastly refused to provide service to African American patrons as a matter of general policy. A little less than a decade later, Congress passed the Civil Rights Act of 1964, Title II of which specifically prohibits discrimination in places of public accommodation that effect commerce.

Following passage of the Civil Rights Act, Rolleston sued the federal government to obtain injunctive relief and bar enforcement of its provisions. He principally claimed that, in passing the law, Congress had exceeded its constitutionally-granted power to regulate commerce. In its landmark unanimous decision Heart of Atlanta Motel v. United States, the Supreme Court on December 14, 1964, firmly upheld the constitutionality of the Civil Rights Act of 1964 and ordered the Heart of Atlanta Motel to cease refusing service to African Americans.

In the majority opinion authored by Justice Tom Clark, the Court decisively held that Congress does have the authority to regulate the transportation of people between states, regardless of whether or not that transportation is purely commercial. The Court also found that this power extends even to the regulation of local incidents which could potentially have a harmful effect on commerce. The Court’s strong defense of the protections established by the Civil Rights Act of 1964 was instrumental in dismantling the structure of racial apartheid in the South.


December 14th, 1922

Harvard University President Defends Exclusion of Black Students from Dorms

On December 14, 1922, Harvard University alumnus Roscoe Bruce received a letter from Harvard President Abbott Lowell regarding Mr. Bruce’s attempts to reserve a freshman dormitory room for his son. “I am sorry to tell you,” wrote Lowell, “that in the Freshman Halls, where residence is compulsory, we have felt from the beginning the necessity of not including colored men.” Mr. Bruce’s son was denied housing according to a policy of racial exclusion that had been in place at Harvard since 1915, when Lowell instituted the requirement that freshmen live on campus. Black students were barred from dorms and dining halls.

Harvard had admitted small numbers of black students intermittently since 1847, and its inclusiveness in that regard was unusual compared to the segregated universities of the South. Educational opportunities were sparse for blacks across the country and it was rare in both the North and South for a black child to make it to high school. In the North, “industrial schools” were built in place of high schools in black communities and black students were encouraged to attend them. Thus, black students accepted into Harvard were a rarified few.

Roscoe Bruce’s father was enslaved in Mississippi before Emancipation and had been elected a United States Senator from Mississippi during Reconstruction. Mr. Bruce graduated from Harvard in 1902 before discriminatory policies like the one used to exclude his son were created. He and other members of the black community wrote to President Lowell in protest. Following World War I, the policy created such a public controversy that it was reported by the national media and alumnae and public figures weighed in on both sides. Despite the backlash, Lowell stood firm on his policy until it was reversed by Harvard’s Board of Overseers in March 1923.

Despite reversal of the policy, black Harvard students indicated that racial separation on campus continued to be enforced informally until at least the 1950s.