Adkins v. Children's Hospital

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Adkins v. Children's Hospital

Argued March 14, 1923
Decided April 9, 1923


Full case name:	Adkins et al., constituting the Minimum Wage Board of the District of Columbia v. Children's Hospital of the District of Columbia; same v. Willie Lyons

Citations:	261 U.S. 525; 43 S. Ct. 394; 67 L. Ed. 785; 1923 U.S. LEXIS 2588; 24 A.L.R. 1238

Prior history:	Dismissed, D.C. Supreme Court; reversed and remanded, 284 F. 613 (D.C. Cir. 1922)

Subsequent history:	None

Holding

Minimum wage law for women violated the due process right to contract freely. D.C. Court of Appeals affirmed.

Court membership

Chief Justice: William Howard Taft
Associate Justices: Joseph McKenna, Oliver Wendell Holmes, Jr., Willis Van Devanter, James Clark McReynolds, Louis Brandeis, George Sutherland, Pierce Butler, Edward Terry Sanford

Case opinions

Majority by: Sutherland
Joined by: McKenna, Van Devanter, McReynolds, Butler
Dissent by: Taft
Joined by: Sanford
Dissent by: Holmes
Brandeis_ took no part in the consideration or decision of the case.

Laws applied

U.S. Const. amends. V, XIX; Minimum Wage Law of the District of Columbia, 40 Stat. 960 (1918)

Overruled by

West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937)

Adkins v. Children's Hospital, 261 U.S. 525 (1923), is a Supreme Court opinion holding that federal minimum wage legislation for women was an unconstitutional infringement of liberty of contract, as protected by the Fifth Amendment. The Court opinion, by Justice Sutherland, held that previous decisions (Muller v. Oregon, 208 U.S. 412 (1908) and Bunting v. Oregon, 243 U.S. 426 (1917)) did not overrule the holding in Lochner v. New York, 198 U.S. 45 (1905), protecting freedom of contract. The Muller cases, Sutherland noted, addressed maximum hours; this case addressed a minimum wage. The maximum hour laws left the parties free to negotiate about wages, unlike this law. Moreover, the minimum wage artificially restricts the employer’s side of the negotiation. Noting a potential horrible, the Court argued that if legislatures were permitted to set minimum wage laws, they would be permitted to set maximum wage laws.

Chief Justice Taft, dissenting, argued that there was no distinction between minimum wage laws and maximum hour laws, considering that these essentially both add up to restrictions on the contract. He noted that Lochner’s limitations had appeared to be overruled in Muller and Bunting.

Justice Holmes, also dissenting, noted that there were plenty of other constraints on contract (e.g. blue laws, usury laws, etc.). He cited the reasonable person standard he had put forth in Lochner: if a reasonable person could see a power in the Constitution, the Court ought to defer to legislation using that power.

Adkins was overturned in West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937).

[edit] See also

List of United States Supreme Court Cases

[edit] References

Zimmerman, J. G. (1991). The jurisprudence of equality: the women's minimum wage, the first Equal Rights Amendment, and Adkins v. Children's Hospital, 1905-1923. The Journal of American History, Vol. 78, No. 1. (Jun., 1991), pp. 188-225.