West Coast Hotel Co. v. Parrish

West Coast Hotel Co. v. Parrish
Argued December 16–17, 1936
Decided March 29, 1937
Full case nameWest Coast Hotel Company v. Parrish, et ux.
Citations300 U.S. 379 (more)
57 S. Ct. 578; 81 L. Ed. 703; 1937 U.S. LEXIS 1119; 1 Lab. Cas. (CCH) ¶ 17,021; 8 Ohio Op. 89; 108 A.L.R. 1330; 1 L.R.R.M. 754; 7 L.R.R.M. 754
Case history
PriorJudgment for defendant, Chelan County Superior Court, November 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936)
SubsequentNone
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 E. Hughes
Associate Justices
Willis Van Devanter · James C. McReynolds
Louis Brandeis · George Sutherland
Pierce Butler · Harlan F. Stone
Owen Roberts · Benjamin N. Cardozo
Case opinions
MajorityHughes, joined by Brandeis, Stone, Roberts, Cardozo
DissentSutherland, joined by Van Devanter, McReynolds, Butler
Laws applied
U.S. Const. amend. XIV; Minimum Wages for Women Act, 1913 Wash. Laws 174
This case overturned a previous ruling or rulings
Adkins v. Children's Hospital (1923)

West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), was a decision by the United States Supreme Court upholding the constitutionality of state minimum wage legislation. The court's decision overturned an earlier holding in Adkins v. Children's Hospital (1923) and is generally regarded as having ended the Lochner era, a period in American legal history during which the Supreme Court tended to invalidate legislation aimed at regulating business.[1]

The case arose when hotel maid Elsie Parrish sued for the difference between her wages and the minimum wage set by the State of Washington. In his majority opinion, Chief Justice Charles Evans Hughes upheld the law, ruling 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. Associate Justice Owen J. Roberts's decision to join the majority in upholding the law after having favored striking down a state minimum wage law in another case has occasionally been referred to as "the switch in time that saved nine" because it occurred during the debate over the Judicial Procedures Reform Bill of 1937.

  1. ^ Philips, Michael J. (2001). The Lochner Court, Myth and Reality: Substantive Due Process from the 1890s to the 1930s. Greenwood. p. 10. ISBN 978-0-275-96930-1.