WEST COAST HOTEL COMPANY V. PARRISH

WEST COAST HOTEL COMPANY V. PARRISH, 300 U.S. 379 (1937), was a decision by the Supreme Court involving the constitutional validity of a Washington State statute creating a commission with power to fix minimum wages for women in the state. The Court thought that the close division by which the case of Adkins v. Children's Hospital (holding a similar act unconstitutional in 1923) had been decided—and changed economic conditions since that case—called for reconsideration of the constitutional issue in question: Does minimum-wage legislation constitute an undue infringement of the freedom of contract guaranteed by the due-process clause of the Fourteenth Amendment?

Chief Justice Charles Evans Hughes, speaking for the Court, reaffirmed the state's authority to interfere in labor contracts where it appeared that the parties were not equal in bargaining power or where the failure to intervene would endanger public health. The Court argued that to deny women a living wage imperiled their health and cast a burden on the community to support them. The enactment of a minimum-wage law for women, said the Court, was not a taking of "liberty" without "due process of law," and the Adkins case, being wrongly decided, should be overruled. Four justices, reiterating the arguments of the Adkins case, dissented. Dramatically ending a series of decisions overturning New Deal legislation, the West Coast Hotel opinion helped establish the legitimacy of federal economic controls and social welfare policies.

BIBLIOGRAPHY

Chambers, John W. "The Big Switch: Justice Roberts and the Minimum Wage Cases." Labor History 10 (1969): 49–52.

Leonard, Charles A. A Search for a Judicial Philosophy. Port Washington, N.Y.: Kennikat Press, 1971.

George W. Goble / a. r.

See also Adkins v. Children's Hospital ; Due Process of Law ; Lochner v. New York ; Minimum-Wage Legislation ; Wages and Hours of Labor, Regulation of ; Women in Public Life, Business, and Professions .