West Coast Hotel Co. v. Parrish
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| West Coast Hotel Co. v. Parrish | |||||||||||||
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| Argued December 16 – 17, 1936 Decided March 29, 1937 |
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| Holding | |||||||||||||
| Washington's minimum wage law for women was a valid regulation of the right to contract freely because of the state's special interest in protecting their health and ability to support themselves. Supreme Court of Washington affirmed. | |||||||||||||
| Court membership | |||||||||||||
| Chief Justice: Charles Evans Hughes Associate Justices: Willis Van Devanter, James Clark McReynolds, Louis Brandeis, George Sutherland, Pierce Butler, Harlan Fiske Stone, Owen Josephus Roberts, Benjamin N. Cardozo |
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| Case opinions | |||||||||||||
| Majority by: Hughes Joined by: Brandeis, Stone, Roberts, Cardozo Dissent by: Sutherland Joined by: Van Devanter, McReynolds, Butler |
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| Laws applied | |||||||||||||
| U.S. Const. amend. XIV; Minimum Wages for Women Act, 1913 Wash. Laws 174 | |||||||||||||
West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), was a decision by the Supreme Court of the United States that upheld the constitutionality of minimum wage legislation enacted by the State of Washington, overturning an earlier decision in Adkins v. Children's Hospital, 261 U.S. 525 (1923).
The Court, in an opinion by Chief Justice Hughes, ruled that the Constitution permitted the restriction of liberty of contract by state law where such restriction protected the community, health and safety or vulnerable groups, as in the case of Muller v. Oregon, 208 U.S. 412 (1908), where the Court had found in favor of the regulation of women's working hours.
Muller, however, was one of the few exceptions of decades of Court invalidation of economic regulation, exemplified in Lochner v. New York, 198 U.S. 45 (1905). West Coast Hotel represents the end of that trend, and came about through a sudden and seemingly inexplicable shift in the voting habits of Justice Roberts. Coming as it did right when President Franklin D. Roosevelt was pushing his "court packing" scheme to weaken the votes of the older anti-New Deal justices, Roberts' move was notoriously referred to as "the switch in time that saved nine," even though Roberts decision was handed in before Roosevelt actually had made his plan public.
Justice Sutherland's dissent contained a thinly veiled admonition to Roberts for switching sides, as well as an insistence that the Constitution does not change by events alone (namely, the Great Depression). The dissent also adhered to the previously dominant perspective that the majority repudiated here: that freedom of contract was the rule with few exceptions, and that the shift of the burden for the poor onto employers was an arbitrary and naked exercise of power. However, the majority's view on economic regulation remains the law of the land today.
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[edit] Further reading
John Ryskamp, The Eminent Domain Revolt: Changing Perceptions in a New Constitutional Epoch, New York: Algora Publishing, 2006.
