West Coast Hotel Co. v. Parrish
Doctrine Established:End of Economic Substantive Due Process / Rational Basis Review for Economic Regulation
Why is West Coast Hotel Co. v. Parrish significant?
West Coast Hotel v. Parrish effectively ended the Lochner era by upholding a state minimum wage law for women and overruling Adkins v. Children's Hospital. The decision marked the beginning of the Court's modern deference to economic regulation and is often called 'the switch in time that saved nine,' as it came during President Roosevelt's court-packing controversy.
Source: Read West Coast Hotel Co. v. Parrish on Google Scholar
Why This Case Matters
West Coast Hotel v. Parrish effectively ended the Lochner era by upholding a state minimum wage law for women and overruling Adkins v. Children's Hospital. The decision marked the beginning of the Court's modern deference to economic regulation and is often called 'the switch in time that saved nine,' as it came during President Roosevelt's court-packing controversy.
Facts
Elsie Parrish was a chambermaid at the Cascadian Hotel in Wenatchee, Washington. She and her husband sued the West Coast Hotel Company to recover the difference between the wages she was paid and the minimum wage set by Washington state law for women and minors. The hotel argued that the minimum wage law violated the Due Process Clause of the Fourteenth Amendment, relying on the Court's prior decision in Adkins v. Children's Hospital, which had struck down a similar federal minimum wage law.
Procedural History
The trial court ruled against Parrish, relying on Adkins. The Washington Supreme Court reversed, upholding the state minimum wage law. The Supreme Court granted certiorari.
Issue
Does a state minimum wage law for women violate the Due Process Clause of the Fourteenth Amendment by impermissibly restricting the freedom of contract?
Holding
The Court upheld the Washington minimum wage law in a 5-4 decision, overruling Adkins v. Children's Hospital. Chief Justice Hughes wrote that the Constitution does not speak of freedom of contract and that the liberty protected by the Due Process Clause is subject to regulation reasonably related to a proper legislative purpose. The exploitation of workers through substandard wages was a legitimate subject of legislative concern.
Reasoning & Analysis
Chief Justice Hughes's opinion held that the Constitution does not guarantee an absolute freedom of contract. Liberty under the Due Process Clause is subject to reasonable regulation in the public interest. The Court held that the legislature was entitled to adopt measures to reduce the evils of the sweating system, and that minimum wage legislation bore a reasonable relation to the legitimate goal of protecting workers from exploitation. The decision recognized that the unequal bargaining position of workers justified legislative intervention.
Dissent
Justice Sutherland, joined by Justices Van Devanter, McReynolds, and Butler, dissented, maintaining that the minimum wage law unconstitutionally impaired the freedom of contract and that the meaning of the Constitution does not change with the shifting of economic winds.
Key Quotes
“The Constitution does not speak of freedom of contract.”
“What is this freedom? The Constitution does not speak of freedom of contract. It speaks of liberty and prohibits the deprivation of liberty without due process of law.”
“The exploitation of a class of workers who are in an unequal position with respect to bargaining power and are thus relatively defenceless against the denial of a living wage is not only detrimental to their health and well being, but casts a direct burden for their support upon the community.”
Legacy & Impact
West Coast Hotel marked the constitutional revolution of 1937 and the end of the Lochner era's judicial hostility to economic regulation. After this decision, the Court applied rational basis review to economic legislation, and no economic regulation has been struck down on substantive due process grounds since. The case cleared the path for the New Deal regulatory state and reshaped the boundary between judicial and legislative power.
Exam Relevance
West Coast Hotel is tested as the bookend to Lochner, marking the shift from active judicial scrutiny of economic regulation to rational basis review. Professors test whether students understand the doctrinal shift and can articulate why the Court abandoned economic substantive due process while later adopting substantive due process for personal liberties.
Study Tips
- 1Understand this case as the end of the Lochner era and the beginning of modern rational basis review for economic regulation.
- 2Know the political context: FDR's court-packing plan and Justice Roberts's 'switch in time.'
- 3Be able to explain the doctrinal tension between abandoning economic substantive due process and later embracing substantive due process for personal autonomy rights.
- 4Compare the majority's and dissent's views on whether constitutional meaning changes with economic conditions.