West Coast Hotel Co. v. Parrish
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| West Coast Hotel Co. v. Parrish | ||||||
 Supreme Court of the United States |
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| Argued December 16–17, 1936 Decided March 29, 1937 |
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| Full case name | West Coast Hotel Company v. Ernest Parrish, et ux. | |||||
| Citations | 300 U.S. 379 (more) 57 S. Ct. 578; 81 L. Ed. 703; 1937 U.S. LEXIS 1119; 1 Lab. Cas. (CCH) P17,021; 8 Ohio Op. 89; 108 A.L.R. 1330; 1 L.R.R.M. 754; 7 L.R.R.M. 754 |
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| Prior history | Judgment for defendant, Chelan County Superior Court, Nov. 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936) | |||||
| Subsequent history | None | |||||
| 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 | ||||||
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| Case opinions | ||||||
| Majority | Hughes, joined by Brandeis, Stone, Roberts, Cardozo | |||||
| Dissent | Sutherland, joined by Van Devanter, McReynolds, Butler | |||||
| 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 upholding 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).
[edit] Background
Elsie Parrish, a chambermaid working at the Cascadian Hotel in Wenatchee, Washington (owned by the West Coast Hotel Company), along with her husband, sued the hotel for the difference between what she was paid, and the $14.50 per week of 48 hours established as a minimum wage by the Industrial Welfare Committee and Supervisor of Women in Industry, pursuant to Washington state law. The trial court, using Adkins as precedent, ruled for the defendant. The Washington Supreme Court, taking the case on a direct appeal, reversed the trial court and found in favor of Parrish. The hotel appealed to the U.S. Supreme Court.
[edit] Decision
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.
The Muller case, however, was one of the few exceptions to 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 an unexpected shift in the voting habit of Associate Justice Roberts. Coming at the time when President Franklin D. Roosevelt was pushing his court reform bill to weaken the votes of the older, anti-New Deal justices, Roberts's move was notoriously referred to as "the switch in time that saved nine."
Associate Justice Sutherland's dissent contained a thinly veiled admonition of Roberts, 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: 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.
Although the majority's view on economic regulation remains the law of the land today, the expansion of Commerce Clause jurisprudence signaled by West Coast Hotel[clarification needed] was reined in slightly by United States v. Lopez, 514 U.S. 549 (1995), and United States v. Morrison, 529 U.S. 598 (2000).
[edit] See also
- Fair Labor Standards Act of 1938
- List of United States Supreme Court Cases
- List of United States Supreme Court cases, volume 300
