West Coast Hotel Co. v. Parrish

West Coast Hotel Co. v. Parrish
Supreme Court of the United States
Argued December 16–17, 1936 Decided March 29, 1937
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
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
Chief Justice Charles E. Hughes Associate Justices Willis Van Devanter · James C. McReynolds Louis Brandeis · George Sutherland Pierce Butler · Harlan F. Stone Owen J. Roberts · Benjamin N. Cardozo
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 United States Supreme Court 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). The decision is usually 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.

Facts

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 $14.30 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.

Judgment

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 shortly after President Franklin D. Roosevelt had proposed his court reform bill to weaken the votes of the older, anti-New Deal justices, although the historical record lends weight to assertions that Roberts' decision happened much earlier, Roberts' 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 is not subject to the perceived necessities of present-day events (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.

See also

• Fair Labor Standards Act of 1938

External links

• Text of West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937) is available from: Justia · Findlaw